HomeMy WebLinkAbout2024-10-02; Planning Commission; ; Climate Action Plan Update. Consideration of a recommendation to the City Council to certify Addendum No. 1 to the Housing Element Implementation and Public Safety ElemenMeeting Date: Oct. 2, 2024
To: Planning Commission
Staff Contact: Katie Hentrich, Senior Program Manager; 442-339-2623;
katie.hentrich@carlsbadca.gov
Subject: Climate Action Plan Update. Consideration of a recommendation to the City
Council to certify Addendum No. 1 to the Housing Element Implementation and
Public Safety Element Update Supplemental Environmental Impact Report for
the Climate Action Plan Update and to recommend the adoption of a Climate
Action Plan Update.
Location: Citywide
Case Numbers: N/A
Applicant/Representative: N/A
CEQA Determination: ☐Not a Project ☐ Exempt ☐ IS/ND or IS/MND ☐ EIR
☒Other: Addendum
Permit Type(s): ☐SDP ☐ CUP ☐ CDP ☐ TM/TPM ☐ GPA ☐ REZ ☐ LCPA
☒Other: N/A
CEQA Status: ☒The environmental assessment IS on the Agenda for discussion
☐A CEQA determination was already issued. That decision is final and
IS NOT on the Agenda
Commission Action: ☐Decision ☒ Recommendation to City Council ☐ Informational (No Action)
Recommended Actions
That the Planning Commission ADOPT the following:
1.A Planning Commission Resolution (Exhibit 1) RECOMMENDING CERTIFICATION of Addendum No. 1 to
the Housing Element Implementation and Public Safety Element Update Supplemental Environmental
Impact Report for the Climate Action Plan Update.
That the Planning Commission ADOPT one of the following:
2.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate
Action Plan Update, excluding Measures E-3.2, E-3.3 and E-4.2 (Nonresidential Building Energy –
Updated Reach Code, Nonresidential Building Energy – Solar Carports, and Residential Building Energy –
Updated Reach Code, respectively)), to meet the required 2045 reduction target (Exhibit 2); OR
3.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate
Action Plan Update, excluding Measure E-3.2 (Nonresidential Building Energy – Updated Reach Code),
which would exceed the 2045 reduction target by approximately 200 MT CO2e (Exhibit 3); OR
Oct. 2, 2024 Item #1 1 of 157
4.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate
Action Plan Update, excluding Measure E-4.2 (Residential Building Energy – Updated Reach Code), which
would exceed the 2045 reduction target by approximately 4,000 MT CO2e (Exhibit 4); OR
5.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate
Action Plan Update, which would exceed the 2045 reduction target by approximately 6,000 MT CO2e
(Exhibit 5).
Background
Why the Climate Action Plan Update is required
On April 6, 2021, the City Council approved a comprehensive update to the city’s Housing Element, including land
use changes to meet the Regional Housing Needs Assessment (RHNA) for Carlsbad. City Council’s approval of the
Housing Element amendments was consistent with the unanimous recommendations of the Planning Commission
and the Housing Commission.
Soon after, on April 13, 2021, staff presented the Climate Action Plan Annual Report for Reporting Period 4 to the
City Council, which was accepted and approved by Resolution No. 2021-083. In the annual report, staff discussed
the need to update the city’s Climate Action Plan to account for the land use and growth changes included in the
Housing Element amendments, and the associated greenhouse gas, or GHG, impacts. By accounting for the GHG
impacts of the Housing Element amendments in the updated Climate Action Plan, the city may continue to rely on
its Climate Action Plan for streamlined development review within the city.
On June 8, 2021, the City Council approved funding for a comprehensive update to the Climate Action Plan, or CAP,
as part of the fiscal year 2021-22 budget. After the city updated its Housing Element and approved funding for the
associated CAP update, there were changes in state law establishing more aggressive GHG targets. Specifically, in
2022, the California Governor signed into law Assembly Bill 1279, the California Climate Crisis Act, which requires
the state to achieve net zero GHG emissions as soon as possible, and to reduce GHG emissions in California by
85% compared to 1990 levels by 2045.1 The Climate Crisis Act does not replace, nor supersede, the state’s
previous GHG reduction target of 40% compared to 1990s levels by 2030.2 The publicly posted Draft CAP update
sets GHG reduction targets for 2035 and 2045 and aligns with state legislation.
On Jan. 30, 2024, the City Council approved Resolution No. 2024-014, certifying the Final Supplemental
Environmental Impact Report (SEIR) for the General Plan Land Use and Community Design Element and Public
Safety Element. The SEIR included Mitigation Measure GHG-1 “Update City of Carlsbad Climate Action Plan”,
requiring the city to draft and the City Council to adopt an updated Climate Action Plan within 12-18 months of
adoption of the SEIR. As such, the period for the City Council to adopt an updated Climate Action Plan is between
January 30, 2025 and July 30, 2025.
At the Sept. 4, 2024, Planning Commission meeting, staff presented an informational report and status update on
the Draft Climate Action Plan Update (Exhibit 2, Attachment A). This staff report serves as a follow-up to that item
and asks the Planning Commission to take action on the Draft Climate Action Plan Update and its associated
addendum.
Purpose of the Climate Action Plan
Climate action plans are comprehensive plans that detail the specific activities that a government agency will
undertake to reduce GHG emissions. They generally focus on those activities that can achieve emissions reductions
within a city’s control to meet state reduction targets. These plans typically include:
1 See Health and Safety Code, Section 38562.2
2 See Health and Safety Code, Section 38566.
Oct. 2, 2024 Item #1 2 of 157
•Specific city-sponsored initiatives and actions that the city controls directly, such as operations and energy
use at city buildings and the types of cars in the city’s fleet.
•State and city policies to direct, guide or influence outside actions, such as a requirement to recycle food
scraps and energy efficiency standards for new building construction.
The City of Carlsbad was one of the first cities in the county to adopt a qualified CAP to support California’s
ambitious GHG emissions reduction goals. On September 22, 2015, the City Council adopted the CAP, along with
the General Plan Update and associated Environmental Impact Report, in compliance with the state’s GHG
reduction target of 40% compared to 1990s levels by 2030.
On July 14, 2020, the City Council adopted the revised CAP, which was amended to revise the GHG inventory and
forecast, update reductions from existing measures, and incorporate community choice energy as a new reduction
measure.3 The 2020 CAP also implements the city’s Guiding Principles and Community Values of Sustainability, as
well as actions identified in the Declaration of a Climate Emergency, approved by the City Council on Sept. 21,
2021, and the Five-Year Strategic Plan.
Overview of methodology
Updating the CAP to account for the approved land use changes in the city and the new reduction targets
established by the state required updating the GHG inventory to reflect the best available data. The starting point
for tracking activities in such a plan is the year it began, known as the “baseline year.” The Draft Climate Action
Plan Update uses 2016 as the baseline year because 2016 provides the most comprehensive, recent and best
available data. The CAP baseline data is consistent with the data sources and custom modeling the city created as
part of implementation of the General Plan Land Use and Community Design Element and Public Safety Element to
implement the requirements of the Housing Element.
Based on the 2016 data (i.e., the baseline year), the city’s total emissions were 981,000 metric tons of carbon
dioxide equivalent, or MT CO2e.4 The top three categories of emissions in Carlsbad are:
1.transportation on roads/streets (basically vehicle travel) at 51%
2.electricity at 27% and
3.natural gas use at 14%, as shown in the chart below.
3 The amendment was necessary to correct a data calculation error related to Vehicle Miles Traveled.
4 The unit CO2e represents an amount of greenhouse gas whose atmospheric impact has been standardized to that one-unit
mass of carbon dioxide (CO2), based on the global warming potential of the gas.
Oct. 2, 2024 Item #1 3 of 157
Carlsbad’s 2016 greenhouse gas inventory
The precise emission reduction totals, and other information, are included as Appendix C in Attachment A to
Exhibit 2, the Draft Climate Action Plan Update.
Projections to determine future emissions
Staff and consultants projected the amount of GHG that would be produced in these categories into the future,
using the 2016 GHG emissions inventory and estimates for population, housing and job growth. This is called the
“business-as-usual” projection, which shows the anticipated growth in emissions from these sources in the
absence of any new policies and programs. Emissions reductions that are expected to result from federal and state
policies and programs are applied to a second set of projections, creating a “legislatively adjusted business-as-usual
projection.”
GHG emissions were projected for the target years 2035 and 2045 using these projections, with 2035 being the
year that Carlsbad’s General Plan anticipates that the city will be fully developed or built out. As shown in the chart
below, the city is projected to meet the 2035 reduction goals based on the legislatively adjusted business-as-usual
assumption, though the city is not projected to meet the 2045 reduction goals unless new measures are
implemented by the city. The chart below shows:
•The business-as-usual projection is shown in green, with GHG emissions continuing unchanged.
•The legislatively adjusted business-as-usual projection is shown in blue, which accounts for the impacts of
federal and state laws and programs to curb emissions.5
•The state’s GHG targets for 2035 and 2045 are shown in yellow.
5 More detailed information on the federal and state laws and programs are included in the legislatively adjusted business-as-
usual calculations are included in Appendix C in Attachment A in Exhibit 2, the Draft Climate Action Plan Update.
Oct. 2, 2024 Item #1 4 of 157
Electricity, 2796
Natural gas, 1496
Other vehicles/equipment, 396
Solid waste, 496
Water treatment/delivery, 196
Wastewater treatment, 0.396
Transportation (on roads/streets), 5196
State’s recommendations
The California Air Resources Board provides the following guidance on how to best set CAP targets:
•Evaluate and adopt robust, locally appropriate emissions goals based on a local GHG emissions inventory
•Express emission goals based on mass GHG emissions reductions
•Show a downward-trending GHG emissions trajectory consistent with the statewide goals
Potential measures in the Draft Climate Action Plan Update
To meet the GHG reduction targets, staff and the consultants analyzed measures for inclusion in the Draft Climate
Action Plan Update using the following guidelines:
•Leverage existing city efforts to defray additional costs and staff time as much as possible
•Include successful and applicable measures from the current CAP, as well as GHG reduction strategies
included in state guidance documents
•Incorporate input from city staff across all departments so the measures can be implemented
•Provide a robust public input process to allow all community priorities to be heard
•Create reportable measures so the CAP Update process is transparent
The Draft Climate Action Plan Update has 25 measures (including 37 primary actions and 69 supporting actions), in
the following categories:
•Water and wastewater
•Energy
•Waste diversion
Oct. 2, 2024 Item #1 5 of 157
1,200,000
981,000 993,000
1,000,000
1,024,000
800,000
..
0 u 600,000 ... 490,000 ~
400,000
200,000
"' ,.._ 00 ~ ~ " N ::l ;;!; :!J "' ,.._ ~ "' 0 " N "' "' "' "' ,.._ 00 "' g " N ! I "' " " " ~ N N N N 8 8 8 8 fl fl fl fl 8 8 g g ~ 0 ~ ~ ~ 0 0 0 0 ~ ~ ~ ~ N N N N N N N N N N N N N N
--Business-as-usu al --Legislatively adjusted ,....Greenhouse gas
business-as-usual reduct ion targets
•Transportation
•Off-road equipment
•Carbon sequestration (or the process of capturing and storing atmospheric carbon dioxide)
The specific measures are included in Chapter 3, Table 3.1, of the Draft Climate Action Plan Update in Exhibit 2,
Attachment A.
Climate Action Plan Update implementation
Mirroring implementation of the city’s currently adopted Climate Action Plan, implementation of the Climate
Action Plan Update would begin after adoption. City staff will need to evaluate and monitor performance over time
and alter or amend the plan if it is not following the emissions trends needed to meet its reduction targets, as part
of the annual reporting process. This will include conducting periodic GHG inventories and analyzing the
performance of measures using quantitative metrics and reporting on implementation activities annually.
The city has published annual CAP reports since 2017. The annual reports include the most recent GHG emissions
data, implementation status of each action, and progress toward achieving the emissions reduction targets. As
technologies and markets change, these reports will continue to be used to track progress and identify actions that
need to be improved, adjusted, or removed.
Finally, the city will prepare future updates to the CAP. Future updates are likely necessary to account for any new
state or federal legislation, measures and actions, as well as any relevant findings and recommendations from the
city’s annual monitoring reports.
Meeting vs. exceeding reduction targets
When combined with the federal and state measures within the legislatively adjusted business-as-usual projection,
the measures in the publicly posted Draft Climate Action Plan Update are projected so that the city will surpass its
2045 reduction target by approximately 6,000 MT CO2e.6 6,000 MT CO2e is equivalent to 0.68% of the total GHG
reductions for 2045.
Preparing a suite of measures that surpasses the 2045 reduction target fulfills comments received from the
individual City Council Members at the Nov. 7, 2023 City Council meeting. More information on those comments is
included in the Public Outreach & Comment section of this staff report.
While the City Council will be asked to make the determination on which option to elect for the Climate Action
Plan Update, staff recommend that the Planning Commission provide a recommendation to the City Council.
Staff have provided four options for the Planning Commission to consider. The difference in the options depends
on whether the Planning Commission would like to recommend that the Climate Action Plan Update meet or
exceed the 2045 reduction targets established by the state.
Options
The Planning Commission is being asked to consider approving one of the following four options listed in the chart
below, with the associated benefits and drawbacks of each option also provided:
6 Three proposed measures in the Draft Climate Action Plan Update are not quantified at this time due to lack of available
data. While these calculations can be updated as policies and programs for those measures progress and as data becomes
available, it is important that the calculations for the remaining measures in the Draft Climate Action Plan Update meet the
Plan’s reduction targets at the time of adoption to fulfill regulatory requirements.
Oct. 2, 2024 Item #1 6 of 157
Option Description Benefits Drawbacks
1 •Recommend adoption
of a CAP Update that
meets the 2045
reduction target.
•Adopts the publicly
posted Draft CAP
Update excluding the
following three
measures:
-E-3.2, Nonresidential
Building Energy –
Updated Reach Code
-E-3.3, Nonresidential
Building Energy –
Solar Carports
-E-4.2, Residential
Building Energy –
Updated Reach Code
•Meets the target completion
date for Mitigation Measure
GHG-1 in the SEIR for the
Housing Element rezone effort.
•Allows for continued
streamlined development
review of projects that show
consistency with the CAP.
•Meets the minimum 2045
reduction target.
•Reflects public comment and
input provided by stakeholders
for the CAP Update.
•Delays implementation of the CAP
Update to revise the documents.
•Implements a smaller suite of
measures to meet the 2045
reduction target, which provides
less flexibility for CAP
implementation.
2 •Recommend adoption
of the publicly posted
Draft CAP Update that
exceeds the 2045
reduction target by
approximately 200 MT
CO2e.
•Adopts the publicly
posted Draft CAP
Update excluding
Measure E-3.2
(Nonresidential
Building Energy –
Updated Reach Code)
•Meets the target completion
date for Mitigation Measure
GHG-1 in the SEIR for the
Housing Element rezone effort.
•Allows for continued
streamlined development
review of projects that show
consistency with the CAP.
•Exceeds the 2045 reduction
target by approximately 200
MT CO2e
•Reflects public comment and
input provided by stakeholders
for the CAP Update.
•Delays implementation of the CAP
Update to update to the
documents.
•Implements a smaller suite of
measures to meet the 2045
reduction target, which provides
less flexibility for CAP
implementation.
3 •Recommend adoption
of a CAP Update that
exceeds the 2045
reduction target by
approximately 4,000
MT CO2e
•Adopts the publicly
posted Draft CAP
Update excluding
Measure E-4.2
(Residential Building
Energy – Updated
Reach Code)
•Meets the target completion
date for Mitigation Measure
GHG-1 in the SEIR for the
Housing Element rezone effort.
•Allows for continued
streamlined development
review of projects that show
consistency with the CAP.
•Exceeds the 2045 reduction
target by approximately 4,000
MT CO2e
•Reflects public comment and
input provided by stakeholders
for the CAP Update.
•Delays implementation of the CAP
Update to update to the
documents.
•Implements a smaller suite of
measures to meet the 2045
reduction target, which provides
less flexibility for CAP
implementation.
Oct. 2, 2024 Item #1 7 of 157
4 •Recommend adoption
of a CAP Update that
exceeds the 2045
reduction target by
approximately 6,000
MT CO2e.
•Adopts the publicly
posted Draft CAP
Update.
•Meets the target completion
date for Mitigation Measure
GHG-1 in the SEIR for the
Housing Element rezone effort.
•Allows for continued
streamlined development
review of projects that show
consistency with the CAP.
•Exceeds the 2045 reduction
target by approximately 6,000
MT CO2e and includes a larger
list of measures for additional
implementation flexibility.
•Includes Reach Codes that
industry stakeholders have
objected to, including on the basis
that the Reach Codes have not
been studied for cost
effectiveness7
Public Outreach & Comment
First phase of public input
The city asked the public to help shape the Draft Climate Action Plan Update in early 2022, by providing input on
environmental sustainability needs and priorities. Three themes emerged from that first phase of public input:
1.Take bold actions to minimize contributions to climate change
2.Consider a range of actions to help reduce GHG emissions, prioritizing reductions from transportation
and energy
3.Promote equity and public awareness to improve quality of life for everyone and encourage people to
drive climate action individually
This public input was used to develop the list of potential measures for inclusion in the Draft Climate Action Plan
Update.
Second phase of public input
From October to November 2023, the city asked the public to share feedback on the proposed GHG reduction
measures and actions. During this second phase of public input, the proposed measures were shared through
various methods, including the city’s website, weekly City Manager emails, stakeholder email list, city social
media platforms, meeting with interested stakeholders, attendance at community events and “pop-up” tabling.
Feedback was also gathered through an online survey that allowed participants to indicate which of the
proposed GHG reduction measures they supported and to provide feedback on why. Based on the survey data
and other public comments received, the themes that emerged from the second public engagement phase
mirrored those same three themes reflected in the first phase and listed above.
Public input
Though certain ideas received broad, general support, other input prompted concerns. Several comments
focused on how the Draft Climate Action Plan Update proposed measures or actions would have a negative
impact on the Carlsbad community. These comments are available in full in Appendix D in Exhibit 2, Attachment
A, the Draft Climate Action Plan Update, and are summarized below:
1.Zero emission vehicle batteries are harmful to the environment and promote inhumane labor practices
7 Prior to providing the necessary approval, the California Energy Commission requires that local jurisdictions demonstrate
that their local ordinance, or Reach Code, saves more energy than current statewide energy standards and is cost effective.
Oct. 2, 2024 Item #1 8 of 157
2.Do not include a Reach Code update
3.Electrification and renewable energy requirements for buildings can be challenging and are expensive
4.Existing transportation demand management requirements have negative impacts on businesses
5.Consider benefits and costs to residents and businesses, especially in relation to proposed requirements
for new buildings
6.Using 2035 as a target year is not aggressive enough and 2030 should be the target year that the city
includes in the Plan
City Council comments
On Nov. 7, 2023, staff presented the proposed measures of the Draft Climate Action Plan to the City Council.
While no formal direction was given, comments from City Council members are listed below and were
addressed as follows:
1.Establish clear, interim benchmarks between the 2035 and 2045 target years for transparency and
accountability. Benchmarks were added into the proposed measures.
2.Add in more measures so the total GHG emissions reduced are higher than the 2045 reduction target.
Three additional measures were added to the Draft Climate Action Plan Update. Two of those measures
proposed updates to the city’s Reach Code, and one of those measures proposes installing solar panels
in city-owned parking lots.
3.Add a measure to install solar in city-owned parking lots. While this was included as a supporting
measure in the proposed measures shared with the public and the City Council, staff moved this from a
supporting measure and made it a stand-alone measure. However, staff were not able to calculate the
greenhouse gas emissions for this measure. This measure would require an analysis of how many
parking lots would be suitable for solar and how large these solar systems could be. Once this analysis is
complete (proposed by 2030 in the Draft Climate Action Plan Update), a reduction calculation could be
added.
4.Add a measure banning artificial turf within the city. Staff had analyzed this as a potential measure
after reviewing comments from the first phase of public input. It was deemed infeasible then since there
were high costs and minimal GHG reductions associated with the action. After the second phase of
public input, staff re-analyzed this measure. Not only did it lack emissions reductions, but the cost to
replace artificial turf was extremely high. Additionally, California Government Code 53087.7 allows cities
to ban artificial turf, if desired. Because of this, staff did not include it in the Draft Climate Action Plan
Update in Exhibit 2, Attachment A.
A public input summary containing more details on Phases 1 and 2 of public engagement, as well as all
comments received during these phases, is included as Appendix D in Attachment A in Exhibit 2, the Draft
Climate Action Plan Update.
Publicly Available Draft Climate Action Plan Update
On July 8, 2024, the city made the Draft Climate Action Plan Update available to the public. The Draft Climate
Action Plan Update was shared through various methods, including the city’s website, weekly City Manager
email, city social media platforms, stakeholder email list, meeting with interested stakeholders, news articles,
and attending community events.8
Stakeholder meetings
Staff met with the following groups once the Draft was shared:
•Building Industry Association of San Diego – North County Legislative Committee
8 Examples of events attended include the Carlsbad Chamber of Commerce’s First Friday Breakfast and the city’s Fix-it Clinic.
Oct. 2, 2024 Item #1 9 of 157
•Building Owners and Managers Association San Diego – Government Affairs Committee
•Carlsbad by the Sea Retirement Community – Conservation Committee
•Carlsbad Community Gardens Collaborative
•Clean Earth 4 Kids
•Clean Energy Alliance
•Climate Action Campaign
•NAIOP, the Commercial Real Estate Development Association – Civic Engagement Committee
•North County Climate Change Alliance
•San Diego County Business Alliance9 - Brainstorm Group
•Sierra Club
•Surfrider San Diego
Public input
Feedback was also gathered via email to staff. Emails received by Sept. 13, 2024, are included in Exhibit 7 and
briefly summarized below. Emails received after this date will be included in the upcoming City Council staff
report packet. Some themes were included in multiple comments, as seen in Exhibit 7, but are only listed once
in the summary below, in no particular order:
•Ban residential burning of wood and debris
•Divest from fossil fuels
•Include energy storage locations for municipal renewable energy projects
•Move up implementation timeframe for several measures
•Replace and ban artificial turf
•Host workshops to educate the public on the Climate Action Plan, in coordination with libraries,
community centers and local schools
•Improve building efficiency by adopting a specific building performance ordinance
•Change “when feasible” to “at end of life” for replacing natural gas equipment at city facilities
•Ban all lawn equipment, not just gas-powered leaf blowers
•Add information on differences between the 2012 inventory in the existing Climate Action Plan when
compared to the 2016 inventory in the Draft Climate Action Plan Update
•Incorporate mode share data for monitoring transportation-related measures
•Clarify which building-related measures go “above and beyond” the state’s building code
•Use more localized data to target diversion of specific waste categories
•Expand Measure T-2 (Transportation Demand Management Program) to address all land uses and lower
the threshold to include more businesses, as well as existing businesses of a certain size
•Add benchmarks for unquantified measures
•Include non-city owned trees (e.g., trees owned by HOAs) in Measure CS-1 (Community Forest
Management)
•Establish a Sustainability Commission
•Set a target date for a zero-carbon reduction goal
•Expand mode-shift goals to meet or exceed 50% alternative modes (so, not driving alone) by 2035
•Promote replacement of gas appliances at end of life for existing residential buildings
•Work with the school districts to implement anti-idling at local schools
•Electrify all city fleet vehicles, including public safety vehicles
•Prioritize Americans with Disabilities Act sidewalk installation improvements connecting to public transit
services and bus stops
9 The San Diego County Business Alliance is a business association coalition that includes numerous groups, including the
California Restaurant Association, California Apartment Association, San Diego County Lodging Association, San Diego North
Economic Development Council, and Building Industry Association of San Diego.
Oct. 2, 2024 Item #1 10 of 157
•Add language to Measure T-6 (Local Transportation Improvements) that references complementing
existing fixed-route bus and rail transit services
•Expand equity considerations as it relates to Measures T-5 (Pedestrian System Improvements) and T-6
(Local Transportation Improvements)
•Create a public-facing dashboard that displays implementation progress for all measures
•Remove invasive plants at parks and lagoons and replace with native plants and natural grasses
•Install solar at all municipal facilities
•Incentivize and recognize businesses that make sustainable choices and developments that incorporate
sustainable design features
•Change threshold for tenant improvements to use intensity of use or percentage of floor area increase
versus a dollar-based threshold
•Decrease ornamental turf and incentivize xeriscaping for lawns and landscaping
•Incentivize private property or landowners to install solar
•Create a fee structure for solid waste disposal similar to proposed updates to the City of San Diego’s
People’s Ordinance
•Provide compost to farms or send to an anaerobic digestion
•Create a percentage reduction goal for local vehicle miles traveled
•Create a bike-sharing program
•Adopt parking management strategies, such as shared or unbundled parking for new developments
•Develop a native plant ordinance
•Incorporate pedestrian safety into sidewalk design
•Design and install a network of Class IV bike lanes
•Consider reducing speed on local roads to encourage use of neighborhood electric vehicles
•Promote apprenticeship programs related to renewable energy
•Do not adopt a suite of measures that go above and beyond the 2045 reduction targets
•Wait until new statewide building code is published prior to adopting new local building code
requirements
•Increase jobs closer to where people live to reduce transportation emissions
•Focus on incentives instead of mandates
•Prepare a benefit-cost analysis that addresses benefits and costs to the public, businesses, etc.
•Lead by example and reduce emissions in city operations
•Do not adopt energy performance-based requirements for buildings (Measures E-3.2 and E-4.2)
•Benchmarking requirements (Measure E-5) are duplicative of state’s requirements
•Clarify that actions for decarbonizing existing buildings (Measure E-6) are voluntary and not banning
natural gas
•Consider phasing in any additional solid or organic waste diversion requirements
•Remove existing Transportation Demand Management requirements for non-residential developments
•Expand transit service
•Ensure additional loads on the local grid can support increase in solar and electric vehicle usage and that
local utilities are able to serve this additional load
•Take no action on parking management strategies (Measure T-10) until completion of the Carlsbad
Village, Barrio, and Beach Area Parking Management Plan update
•Equipment cost and availability for alternative-fuel construction equipment (Measure OR-2) are
burdensome
Response to Public Comment and Project Issues
First phase of public input
As discussed previously in the staff report, the public input gathered during the first phase was used to develop
the list of potential measures for inclusion in the Draft Climate Action Plan Update.
Oct. 2, 2024 Item #1 11 of 157
Second phase of public input
As discussed above, comments were received from the City Council at the Nov. 7, 2023, meeting. Several other
comments were received from the public during this phase. The public input summary included as Appendix D in
Attachment A of Exhibit 2, the Draft Climate Action Plan Update, has more details on public comments received
and the response to comments during the first and second phase of public input.
Project Analysis
State regulations
The Draft CAP Update is consistent with the guidance prepared by the California Air Resources Board, as well as
targets set by California’s Legislature.
General Plan consistency
The City of Carlsbad General Plan includes several goals and policies related to sustainability. The Draft CAP
Update directly supports these goals and policies, as well as guiding principles and core values embedded in the
General Plan. Several General Plan elements include sustainability goals and policies as well, including the Land
Use and Community Design, Mobility, Safety, and Open Space, Conservation, and Recreation elements.
The 2015 CAP was included as a mitigation measure in the 2015 General Plan Update Environmental Impact
Report to mitigate impacts to GHG. More recently, the Housing Element Implementation and Public Safety
Element Update Supplemental Environmental Impact Report included the Draft CAP Update as a mitigation
measure with a target completion date of no later than July 2025.
Climate Change Emergency Declaration consistency
On Sept. 21, 2021, the City Council approved a Declaration of a Climate Emergency (Resolution No. 2021-215).
This resolution is an acknowledgement of how climate change is affecting the community and stresses the
urgency with which the city needs to act to address these impacts.
Five-Year Strategic Plan consistency
On Oct. 11, 2022, the City Council approved a Five-Year Strategic Plan to focus its resources on community and
Council goals. The following strategic goals support the Carlsbad Community Vision: community character,
quality of life and safety, sustainability and the natural environment, economic vitality, and organizational
excellence and fiscal health. Each goal is categorized by objectives, projects and service commitments. The first
strategic objective within the sustainability and the natural environment section is completing a Draft Climate
Action Plan Update to address the ongoing impacts of climate change.
Environmental Review
In accordance with the California Environmental Quality Act (CEQA), the CEQA Guidelines, and the
environmental protection procedures of the Carlsbad Municipal Code (Title 19), the Climate Action Plan (2015)
was originally evaluated in the General Plan Update and Climate Action Plan Final Program Environmental
Impact Report, certified September 2015. This report evaluated the potential environmental effects of
implementing the greenhouse gas reduction measures contained in the 2015 Climate Action Plan. The Draft
Climate Action Plan Update was evaluated in the Housing Element Implementation and Public Safety Element
Update Supplemental Environmental Impact Report, certified January 2024.
The potential environmental impacts of the Draft Climate Action Plan Update are within the scope of the
previously certified CEQA documents and none of the conditions requiring subsequent or supplemental
environmental review under CEQA Guidelines section 15162 exists. In addition, since only minor or technical
changes to the previously certified EIRs were necessary, an addendum was prepared pursuant to CEQA
Guidelines section 15164. The addendum demonstrates that the Draft Climate Action Plan Update will not result
in any potentially significant impacts to the environment.
Oct. 2, 2024 Item #1 12 of 157
According to CEQA Guidelines section 15164(c), the addendum does not require circulation for public review.
However, the addendum was posted on the city’s website to accompany the public draft of the Draft Climate
Action Plan Update for informational purposes.
Conclusion
The Draft CAP Update implements General Plan goals and policies, mitigates for environmental impacts from other
city programs, fulfills state regulatory requirements, and updates the CAP to align with more recent state
legislation, incorporates best available data, and furthers the community’s goal of promoting a sustainable
environment.
Staff have found the project, including its environmental document, to be consistent with all applicable policies
and requirements.
Based on the contents of this staff report, including the attached exhibits, staff recommend the Planning
Commission adopt a resolution (Exhibit 1) recommending certification of Addendum No. 1 to the Housing Element
Implementation and Public Safety Element Update Supplemental Environmental Impact Report for the Climate
Action Plan Update to the City Council.
Staff also recommend the Planning Commission adopt a resolution recommending adoption of one of the four
provided options for the CAP Update. The resolution recommending adoption of the CAP Update depends on
whether the Planning Commission wishes to recommend a CAP Update that either meets or exceeds the 2045
reduction targets. These resolution options are outlined below:
Option 1
The Planning Commission may wish to recommend that the City Council adopt a CAP Update that meets the
required 2045 reduction target (Exhibit 2). This can be done by recommending adoption of a Climate Action Plan
Update with the suite of measures in the publicly posted Draft CAP Update excluding the following three
measures:
1. E-3.2, Nonresidential Building Energy – Updated Reach Code
2. E-3.3, Nonresidential Building Energy – Solar Carports
3. E-4.2, Residential Building Energy – Updated Reach Code
Options 2 and 3
The Planning Commission may wish to recommend that the City Council adopt a Climate Action Plan Update that
exceeds the 2045 reduction targets, but by less than 6,000 MT CO2e or 0.68%. This can be done by recommending
certain measures in the publicly posted Draft CAP Update be excluded. The two options are:
• Option 2: exclude Measure E-3.2 (Nonresidential Building Energy – Updated Reach Code) from the
Climate Action Plan Update (Exhibit 3)
o This would exceed the 2045 reduction target by approximately 200 MT CO2e, or 0.02%
• Option 3: exclude Measure E-4.2 (Residential Building Energy – Updated Reach Code) from the Climate
Action Plan Update (Exhibit 4)
o This would exceed the 2045 reduction target by approximately 4,000 MT CO2e, or 0.45%
Option 4
The Planning Commission may wish to build upon the comments made at the Nov. 7, 2023, City Council meeting
and recommend adoption of a Climate Action Plan Update that exceeds the 2045 reduction target by
approximately 6,000 MT CO2e, or what is proposed in the latest publicly posted Draft CAP Update. This would
mean exceeding the 2045 reduction target by approximately 0.68%. This can be done by recommending that the
City Council adopt the July 2024 public Draft of the Climate Action Plan as posted (Exhibit 5).
Oct. 2, 2024 Item #1 13 of 157
City Council approval
The City Council is the approving body of the CAP Update. Considering the recommendation of the Planning
Commission, the City Council will conduct a public hearing and act on the proposed action. This is anticipated to
occur in November 2024.
Exhibits
1.Planning Commission Resolution – Addendum to the SEIR
2.Planning Commission Resolution – Climate Action Plan Update, Option 1
3.Planning Commission Resolution – Climate Action Plan Update, Option 2
4.Planning Commission Resolution – Climate Action Plan Update, Option 3
5.Planning Commission Resolution – Climate Action Plan Update, Option 4
6.Sept. 4, 2024, Planning Commission staff report (on file in the office of the City Clerk)
7.Public feedback received on Draft Climate Action Plan Update by Sept. 13, 2024
Oct. 2, 2024 Item #1 14 of 157
PLANNING COMMISSION RESOLUTION NO.7520
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
CARLSBAD, CALIFORNIA, RECOMMENDING CERTIFICATION OF
ADDENDUM NO. 1 TO THE HOUSING ELEMENT IMPLEMENTATION
AND PUBLIC SAFETY ELEMENT UPDATE SUPPLEMENTAL
ENVIRONMENTAL IMPACT REPORT FOR THE CLIMATE ACTION
PLAN UPDATE
CASE NAME: CLIMATE ACTION PLAN UPDATE
CASE NO: N/A
WHEREAS, on Sept. 22, 2015, the City Council adopted a Climate Action Plan along with
the General Plan Update with Resolution No. 2015-244; and
WHEREAS, on Sept. 22, 2015, the City Council certified the Final Program Environmental
Impact Report for the General Plan Update and Climate Action Plan, State Clearinghouse Number
2011011004 (EIR 13-02), with Resolution No. 2015-242; and
WHEREAS, EIR 13-02 evaluated the potential environmental effects of implementing the
greenhouse gas reduction measures contained in the 2015 Climate Action Plan; and
WHEREAS, on Jan. 30, 2024, the City Council certified the Supplemental Environmental
Impact Report for the 2023 Housing Element Implementation and Public Safety Element Update,
State Clearinghouse Number 2022090339 (EIR 2022-0007) through adoption of Resolution 2024-
0014; and
WHEREAS, EIR 2022-0007 evaluated the potential environmental effects of implementing
the greenhouse gas reduction measures contained in the Climate Action Plan Update; and
WHEREAS, the city has determined that EIR 13-02 and EIR 2022-0007 are of continuing
informational value and that the potential environmental impacts of the Climate Action Plan
Update are within the scope of these previously certified documents; and \
WHEREAS, the city has determined that none of the conditions requiring subsequent or
supplemental environmental review under CEQA Guidelines section 15162 exist for the Climate
Action Plan Update; and
WHEREAS, an addendum to EIR 2022-0007 was prepared and indicated no significant
environmental impacts would occur as a result of implementing the Climate Action Plan Update.
Exhibit 1
Oct. 2, 2024 Item #1 15 of 157
Oct. 2, 2024 Item #1 16 of 157
NOW, THEREFORE, BE IT HEREBY RESOLVED by the Planning Commission of the
City of Carlsbad, as follows:
A) That the above recitations are true and correct.
B) Record and basis for action. The Planning Commission has considered the full
record before it, which includes the Record of Proceedings. Furthermore, the
recitals set forth above are found to be true and correct and material to this
resolution; and are incorporated herein by reference.
C) That the addendum to EIR 2022-0007 is adequate and provides good-faith
disclosure of available information on the project and all reasonable and feasible
alternatives thereto. The addendum to EIR 2022-0007 found no significant
environmental impacts would occur as a result of the Climate Action Plan
Update.
F) That based on the evidence presented at the public hearing, the Commission
RECOMMENDS CERTIFICATION of ADDENDUM NO. 1 TO THE HOUSING ELEMENT
IMPLEMENTATION AND PUBLIC SAFETY ELEMENT UPDATE SUPPLEMENTAL
ENVIRONMENTAL IMPACT REPORT FOR THE CLIMATE ACTION PLAN UPDATE -
based on the following findings:
Findings:
1. The Planning Commission has reviewed, analyzed, and considered Addendum No. 1 to
Final EIR 2022-0007 (Attachment A) prior to recommending approval of this project.
2. Based upon the evidence submitted and as demonstrated by the analysis included in the
Addendum No. 1 to Final EIR 2022-0007, none of the conditions described in CEQA
Guidelines Sections 15162 or 15163 calling for the preparation of a subsequent or
supplemental EIR or negative declaration have occurred; specifically:
a. The proposed modifications to the project do not create substantial changes that
would require major revisions to the EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously
identified significant effects; and
b. The proposed modifications to the project do not create substantial changes with
respect to the circumstances under which the project is undertaken that will
require major revisions of the previous EIR due to the involvement of new
significant environmental effects or a substantial increase in the severity of
previously identified significant effects; and
c. There is no new information of substantial importance, which was not known and
could not have been known with the exercise of reasonable diligence at the time
the EIR was certified as complete and adopted, that shows any of the following:
i. The modifications will have one or more significant effects not discussed
in the certified EIR;
ii.Significant effects previously examined will be substantially more severe
than shown in the certified EIR;
iii.Mitigation measures or alternatives previously found not to be feasible
would in fact be feasible and would substantially reduce one or more
significant effects of the project, but the Applicant declines to adopt the
mitigation measure or alternative; or
iv.Mitigation measures or alternatives that are considerably different from
those analyzed in the certified EIR would substantially reduce one or more
significant effects on the environment, but the Applicant declines to adopt
the mitigation measure or alterative; and
v.The evaluation of the proposed modifications to the project, certified EIR,
and Addendum reflects the Planning Commission's independentjudgment and analysis based on review of the entirety of the
administrative record, which record provides the information upon which
this resolution is based.
d.Pursuant to the above findings, the Planning Commission determines that the EIR
(EIR 13-02) and SEIR (EIR 2022-0007), together with the Addendum, satisfy all the
requirements of CEQA and is adequate to serve as the required environmental
documentation for the project.
3.The Planning Commission finds that the Addendum No. 1 to Final EIR 2022-0007 reflects
the City of Carlsbad's independent judgment and analysis, has been prepared in
accordance with requirements of the California Environmental Quality Act, the State
CEQA Guidelines, and the Environmental Review Procedures of the City of Carlsbad and,
therefore, the Planning Commission hereby recommends that Addendum No. 1 to the
Final EIR 2022-0007 be certified in relation to the project.
4.Pursuant to Public Resources Code Section 21081.6(a)(2) and CEQA Guidelines Section
15091(e), the documents and other materials which constitute the record of
proceedings on which this resolution is based are in the City of Carlsbad, at 1200
Carlsbad Village Drive in the custody of the City Clerk, and at 1635 Faraday Avenue in
the custody of the City Planner.
Oct. 2, 2024 Item #1 17 of 157
Oct. 2, 2024 Item #1 18 of 157
PASSED, APPROVED, AND ADOPTED at a regular meeting of the Planning Commission of the City
of Carlsbad, California, held on Oct. 2, 2024, by the following vote, to wit:
AYES: Kamenjarin, Danna, Hubinger, Lafferty, Meenes, Merz, Stine
NAYES: None.
ABSENT: None.
ABSTAIN: None.
on
CARLSBAD P ISSION
ATTEST:
ERIC LARDY
City Planner
City of Carlsbad
Addendum No. 1 to the Housing Element
Implementation and Public Safety
Element Update Supplemental
Environmental Impact Report for the
Climate Action Plan Update
prepared for
City of Carlsbad
1635 Faraday Avenue
Carlsbad, California 92008
prepared by
Ascent, Inc.
1230 Columbia Street, Suite 440
San Diego, CA 92101
Public Review Draft
Attachment A
Oct. 2, 2024 Item #1 19 of 157
(i) .
.
Oct. 2, 2024 Item #1 20 of 157
Table of Contents
Executive Summary ......................................................................................................................................... iii
1 Introduction and Project Summary ........................................................................................................... 1
2 Project Context ...................................................................................................................................... 13
3 Overview of the CEQA Guidelines .......................................................................................................... 15
4 Environmental Effects and Determinations ........................................................................................... 17
5 Addendum Methodology ....................................................................................................................... 18
6 Addendum Evaluation ........................................................................................................................... 19
7 References ............................................................................................................................................. 87
Tables
Table 1 Summary of CAP Update Measures and Actions ................................................................ 4
Figures
Figure 1 Regional Location and Project Vicinity ............................................................................... 2
Oct. 2, 2024 Item #1 21 of 157
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Oct. 2, 2024 Item #1 22 of 157
Executive Summary
The Project consists of an update to the City of Carlsbad’s Climate Action Plan (CAP Update). The city’s
CAP Update outlines goals, strategies, and actions for reducing emissions and combating climate
change. The current CAP, approved as part of the 2015 General Plan and amended in July 2020,
ensures that Carlsbad does its part to contribute to the goals of AB 32 and its successor legislation, SB
32, to reduce its GHG emissions to 1990 levels by 2020, and to 40 percent below 1990 by 2030. The
horizon year for the current CAP is 2035, corresponding with the buildout year of the 2015 General
Plan.
The CAP Update contains strategies to reduce local greenhouse gas (GHG) emissions and streamline
environmental review of future development projects in the city in accordance with the California
Environmental Quality Act (CEQA) such that new development is designed and built following
sustainable practices. This is the city’s second comprehensive update to the CAP, following the CAP
Amendment No. 1 in July 2020 and the original CAP which was adopted in September 2015. CAP
strategies reflect the goals and policies of the city’s General Plan, addressing topics such as increasing
energy efficiency, expanding bicycle and pedestrian infrastructure, and achieving solid waste reduction.
The CAP Update establishes measures and actions to assist the City of Carlsbad in achieving its GHG
emission reduction targets. The CAP Update includes measures organized into six sectors: water and
wastewater, energy, waste diversion, transportation, off-road equipment, and carbon sequestration.
These sectors serve as a way to organize GHG reduction measures and indicate the focus areas of the
associated measures. Within each measure there are one or more actions that define activities, programs,
policies, or projects that the city government will implement or support to achieve CAP Update goals.
In considering the potential environmental impacts of the CAP Update, the city has determined that the
EIR certified for the 2015 General Plan update (General Plan & Climate Action Plan Environmental
Impact Report, State Clearinghouse Number 2011011004, dated June 2015) and SEIR certified for the
2023 Housing Element Implementation and Public Safety Element Update (Housing Element
Implementation and Public Safety Element Update Supplemental Environmental Impact Report, State
Clearinghouse Number 2022090339, dated July 2023) are of continuing informational value. Further,
the city has determined that the potential environmental impacts (both direct and indirect impacts)
of the CAP Update are within the scope of the previously certified CEQA documents, and that none of
the conditions requiring subsequent or supplemental environmental review under CEQA Guidelines
section 15162 exists. Based on the information and analysis provided below, the city has determined
that only minor or technical changes to the previously certified EIRs are necessary and that preparation
of an Addendum pursuant to CEQA Guidelines section 15164 is appropriate. This Addendum was
prepared as a first-tier CEQA document to “adequately address” the direct and indirect physical
environmental effects of CAP Update implementation, including implementation ordinances, so the
city can focus analysis in second-tier documents and implementation actions on issues specific to later
projects. Agencies can adopt General Plan or zoning policies, and apply those policies to specific
projects that are consistent with the General Plan or zoning ordinance (Public Resources Code section
21083.3). Under such circumstances, if an impact is not peculiar to the project, then issues addressed
by those policies are statutorily exempt from further CEQA review. Based on the general nature of its
measures and actions, the CAP Update is analyzed herein to determine whether it could cause a direct
or reasonably foreseeable indirect change in the environment.
Oct. 2, 2024 Item #1 23 of 157
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Oct. 2, 2024 Item #1 24 of 157
1 Introduction and Project Summary
Project Title
Addendum No. 1 to the Housing Element Implementation and Public Safety Element Update
Supplemental Environmental Impact Report (SEIR) for the Climate Action Plan Update (the “Project”
which is also referred to herein as the “CAP Update”)
Lead Agency Name and Address
City of Carlsbad
1635 Faraday Avenue
Carlsbad, California 92008
Contact Person and Phone Number
Katie Hentrich, Senior Program Manager, (442) 339-2623
Project Location
The City of Carlsbad encompasses approximately 39 square miles of land in northwest San Diego
County and is surrounded by Oceanside to the north, Vista, San Marcos, and unincorporated areas of
San Diego County to the east, Encinitas to the south, and the Pacific Ocean to the west. Along
Carlsbad’s northern edge, urban development abuts Highway 78, with the roadway and Buena Vista
Lagoon acting as a boundary between Carlsbad and Oceanside. Similarly, Bat Iquitos Lagoon, along the
city’s southern edge, acts as a boundary between Carlsbad and Encinitas. To the east, boundaries are
less distinct, as a mix of hillsides and urban development are adjacent to Vista, San Marcos, and
unincorporated County lands. The CAP Update planning boundary is the Carlsbad city limits, which is
depicted on Figure 1.
Project Sponsor’s Name and Address
City of Carlsbad
1635 Faraday Avenue
Carlsbad, California 92008
Oct. 2, 2024 Item #1 25 of 157
Figure 1 Regional Location and Project Vicinity
Oct. 2, 2024 Item #1 26 of 157
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Project Description
The City of Carlsbad (City) strives to reduce its contribution to climate change through policy
frameworks that pursue the community’s goal of promoting a sustainable environment. The Climate
Action Plan Update (CAP Update) serves to continue and elevate this policy framework by realigning
its climate action policies with the most recent technological advancements, best practices, and State
legislation. The CAP Update is organized into the following chapters:
• Chapter 1, Introduction. The introduction provides an overview of the effects of global
climate change, describes the extensive and targeted outreach to engage community
members to ensure that the planning process is inclusive and representative of various needs
and viewpoints, and provides background for the city’s climate action planning process.
• Chapter 2, Greenhouse Gas Emissions Inventory, Forecasts, and Targets. This chapter
inventories the city’s GHG emissions to demonstrate the city’s overall contribution to climate
change and the contribution of individual GHG emissions sources and forecasts how
emissions are expected to change with future growth. This chapter presents the technical
basis for the CAP Update, and sets Carlsbad-specific GHG reduction targets for 2035 and
2045 that align with State legislation.
• Chapter 3, Greenhouse Gas Reduction Strategies and Measures. This chapter presents six
strategies and 25 measures that will reduce GHG emissions and build resilience to climate
impacts in the community (i.e., GHG reduction strategies). The strategies are organized into
six sectors: water and wastewater, energy, waste diversion, transportation, off-road
equipment, and carbon sequestration.
• Chapter 4, Implementation and Monitoring. Building off the information in Chapter 3, this
chapter outlines the process by which the city will implement CAP Update strategies and
measures, and how progress will be monitored over time to ensure the CAP Update is
effective in reducing emissions.
The CAP Update contains strategies to reduce local greenhouse gas (GHG) emissions and streamline
environmental review of future development projects in the city in accordance with the California
Environmental Quality Act (CEQA) such that new development is designed and built following
sustainable practices. The CAP Update is the city’s second comprehensive update to the CAP, following
the CAP Amendment No. 1 in July 2020 and the original CAP adopted in September 2015 as part of the
2015 General Plan. CAP strategies reflect the goals and policies of the city’s General Plan, addressing
topics such as increasing energy efficiency, expanding bicycle and pedestrian infrastructure, and
achieving solid waste reduction.
The CAP Update establishes measures and actions that would reduce GHG emissions in Carlsbad to
levels that achieve its GHG reduction targets, which are aligned with the State’s GHG reduction goals.
The city’s 2035 target requires GHG emissions to be reduced 50 percent below 2016 levels (aligned
with and extrapolated from SB 32) and reduced to 85 percent below 2016 levels by 2045 (aligned with
AB 1279). The CAP Update measures and actions are identified in Table 1. The measures and actions
meet the city’s GHG reduction targets.
The CAP Update meets the requirements for a qualified plan for the reduction of greenhouse gas
emissions under State CEQA Guidelines Section 15183. for use in cumulative impact analysis pertaining
to development projects. This Addendum No. 1 is intended to be used for future project-specific GHG
emissions analyses by providing the appropriate level of environmental review to allow for future
projects to tier from and streamline their analysis of GHG emissions pursuant to CEQA Guidelines
Oct. 2, 2024 Item #1 27 of 157
Section 15183.5(b)(2), unless otherwise determined to be cumulatively considerable. CEQA provides
a variety of devices available to streamline the environmental review process and avoid redundancy.
This Addendum No. 1 was also prepared to function as a first-tier CEQA document that would
“adequately address” the direct and indirect physical environmental effects of GHG reduction
measures including implementation ordinances so that city can focus the analysis in its second-tier
documents and implementation actions solely on the issues specific to the later project. Pursuant to
Public Resources Code section 21083.3, agencies can adopt General Plan or zoning policies, and apply
those policies to specific projects that are consistent with the General Plan or zoning ordinance. Under
such circumstances, if the impact at issue is not peculiar to the parcel or project, then the particular
issues addressed by those policies are statutorily exempt from further CEQA review. Based on the
“general nature” of the proposed measures and actions, the CAP Update is analyzed herein as to
determine whether the activity could cause a direct or reasonably foreseeable indirect change in the
environment.
Table 1. Summary of CAP Update Measures and Actions
Transportation
Measure T-1: Traffic Calming & Optimization
Primary Actions
Action T-1.a: Continue optimizing traffic signals within the city, adjusting as needed as traffic volumes and
conditions change, and coordinating along major corridors.
Action T-1.b: Install roundabouts or traffic circles when feasible, utilizing the city’s engineering standard for
intersection control.
Supportive Actions
Action T-1.c: Leverage the Sustainable Mobility Plan and Intersection Control Evaluation engineering
standards to determine the location of new roundabouts and traffic circles.
Measure T-2: Transportation Demand Management Program
Primary Actions
Action T-2.a: Continue implementing and enforcing existing TDM program and enforcing existing TDM
ordinance (adopted 2019), mandating TDM improvements and strategies for non-residential development.
Action T-2.b: Update TDM ordinance to modify existing threshold for compliance (e.g., reducing average
daily trips threshold) as well as streamlining of other reporting requirements, as appropriate, by 2045.
Supportive Actions
Action T-2.c: Continue surveying businesses, pursuant to the TDM ordinance, to monitor implementation
and track compliance.
Action T-2.d: Update TDM strategies in the TDM program as new technology emerges.
Action T-2.e: Leverage Carlsbad Commuter and other city channels to educate commuters on alternative
commute choices and resources available.
Measure T-3: Safe Routes to School
Primary Actions
Action T-3.a: Continue implementing a Safe Routes to School program to encourage walking and biking to
school.
Supportive Actions
Action T-3.b: Leverage the city’s Sustainable Mobility Plan to determine location-specific improvements.
Action T-3.c: Seek funding to launch Safe Routes to Schools programs at additional school sites.
Oct. 2, 2024 Item #1 28 of 157
Table 1. Summary of CAP Update Measures and Actions
Action T-3.d: Leverage the Sustainable Mobility Plan to conduct Safe Routes to School-related education and
outreach activities at schools throughout the city.
Measure T-4: Bikeway System Improvements
Primary Actions
Action T-4.a: Construct 7.9 added miles of Class I multi-use bike paths.
Action T-4.b: Improve 61.2 miles of Class II bike lanes to Class II buffered bike lanes.
Action T-4.c: Continue other bikeway system improvements, as available.
Supportive Actions
Action T-4.d: Leverage the city’s Sustainable Mobility Plan to determine location of bikeway system
improvements and secure bike parking and/or storage.
Action T-4.e: Explore launch of a local on-demand microstransit program, such as the City of Oceanside’s program.
Action T-4.f: Evaluate the city’s Supportive Bicycle Infrastructure, such as adding new bicycle parking at highly
used coastal destinations, bike repair stations, and additional bike-related amenities.
Measure T-5: Pedestrian System Improvements
Primary Actions
Action T-5.a: Add 6.19 miles of sidewalk.
Supportive Actions
Action T-5.b: Utilize the city’s Sustainable Mobility Plan to identify suitable locations for pedestrian system
improvements, focusing on creating safer and more user-friendly infrastructure to facilitate ease of use for
pedestrians.
Measure T-6: Local Transportation Improvements
Primary Actions
Action T-6.a: Explore local transportation improvements to provide sustainable on-demand, flexible fleet
transit and first-mile last-mile solutions.
Action T-6.b: Leverage the Multimodal Transportation Impact Fee for implementation of local transportation
improvements.
Supportive Actions
Action T-6.c: Leverage existing regional transportation plans (e.g., North County Comprehensive Multimodal
Corridor Plan, SANDAG Regional Transportation Plan) to add or update improvements to the transportation
system within Carlsbad
Action T-6.d: Coordinate with regional and local agencies and partners on influencing transportation
improvements throughout the region and within Carlsbad.
Measure T-7: Municipal Transportation Demand Management
Primary Actions
Action T-7.a: Continue implementing existing Transportation Demand Management programs for eligible
city staff.
Supportive Actions
Action T-7.b: Explore establishing new Transportation Demand Management programs for city staff,
resulting in Transportation Demand Management plans for city facilities.
Oct. 2, 2024 Item #1 29 of 157
Table 1. Summary of CAP Update Measures and Actions
Measure T-8: Increase Public Zero Emission Infrastructure
Primary Actions
Action T-8.a: Increase the number of zero emission miles traveled within the city by installing and
incentivizing public zero emission vehicle and bicycle infrastructure.
Supportive Actions
Action T-8.b: Seek external funding and/or partnerships for installation of zero emission vehicle and bicycle
infrastructure (e.g., Clean Energy Alliance customer programs).
Action T-8.c: Explore creation of incentive programs for new construction and existing buildings to install
zero emission vehicle and bicycle infrastructure beyond building code requirements.
Action T-8.d: Continue education and outreach on zero emission vehicle options and rebates.
Action T-8.e: Update existing Electric Vehicle Siting Plan to incorporate additional sites for zero emission
vehicle and bicycle infrastructure, as well as new technologies, expanded zero emission vehicle types, and
best practices.
Action T-8.f: Explore employee purchase programs to encourage workplace charging for city staff.
Measure T-9: Zero Emission City Fleet
Primary Actions
Action T-9.a: Continue transition and expansion of the city’s zero emission fleet.
Action T-9.b: Install zero emission charging infrastructure to support fleet conversion and deployment
needs.
Supportive Actions
Action T-9.c: Establish city fleet regulations for idling.
Action T-9.d: Plan for fleet conversion and deployment, including updates to technology, legislation, and
other best practices.
Action T-9.e: Research technology options and purchase technology to sustain city fleet operations during
emergencies.
Action T-9.f: Transition all passenger fleet vehicle purchases after FY 2022-23 to be electric vehicles, with the
exception of public safety vehicle purchases, which will be electric where feasible.
Action T-9.g: Update city policies to encourage use of zero emission vehicles wherever feasible.
Measure T-10: Parking Management Strategies
Primary Actions
Action T-10.a: Reduce vehicle miles traveled per capita citywide through parking management strategies.
Supportive Actions
Action T-10.b: Implement and update city’s parking management strategies (e.g., Carlsbad Village, Barrio,
and Beach Areas Parking Management Plan, Village and Barrio Master Plan) to encourage alternative modes
of transportation throughout the city.
Energy
Measure E-1: Renewable Electricity at Municipal Facilities
Primary Actions
Action E-1.a: Increase percentage of renewable electricity purchased for existing city facilities and street and
safety lighting to 100%.
Oct. 2, 2024 Item #1 30 of 157
Table 1. Summary of CAP Update Measures and Actions
Action E-1.b: Have 100% renewable electricity be the default for new city facilities and street and safety
lighting.
Action E-1.c: Eliminate natural gas use at city facilities, where feasible.
Supportive Actions
Action E-1.d: Coordinate with the city’s energy suppliers on the purchase of 100% renewable electricity (e.g.,
“Green Impact” level from Clean Energy Alliance).
Action E-1.e: Continue certifying city facilities in the Carlsbad Green Business Program.
Action E-1.f: Conduct analysis to determine best practices and technologies for eliminating natural gas use
at city facilities.
Action E-1.g: Leverage local and regional partnerships and seek funding to support identified renewable
electricity upgrades and elimination of natural gas use at city facilities.
Action E-1.h: Upgrade all street and safety lighting to more energy efficient options.
Measure E-2: Community Choice Energy
Primary Actions
Action E-2.a: Continue the participation in the Clean Energy Alliance (CEA) Community Choice Energy
program.
Action E-2.b: Set 100% renewable electricity (e.g., CEA’s “Green Impact”) as the default option for CEA
customers within the city.
Supportive Actions
Action E-2.c: Explore the purchase of renewable energy credits if CEA is not reaching its 2035 goal.
Action E-2.d: Support promotion of CEA’s customer programs and encourage CEA customers to participate.
Measure E-3: Nonresidential Building Energy
Measure E-3.1: Nonresidential Building Energy Existing Reach Code
Primary Actions
Action E-3.1.a: Continue implementing existing building energy efficiency and water heater ordinances
(adopted in 2019).
Supportive Actions
Action E-3.1.b: Analyze feasibility of eligible sites for renewable energy infrastructure across all city facilities,
leveraging any pre-existing analyses that are applicable.
Action E-3.1.c: Seek grant funding for installation of renewable energy infrastructure at existing and new city
facilities (e.g., solar, battery storage, microgrids).
Measure E-3.2: Nonresidential Building Energy – Updated Reach Code
Primary Actions
Action E-3.2.a: Update city’s building code, or “reach code,” to include updated energy performance-based
requirements for new nonresidential buildings.
Supportive Actions
Action E-3.2.b: Leverage CEA and SDG&E customer programs, or other similar programs.
Action E-3.2.c: Explore pilot programs and incentives to educate businesses on energy efficiency and
renewable energy options for new and existing buildings.
Measure E-3.3: Nonresidential Building Energy – Solar Carports
Oct. 2, 2024 Item #1 31 of 157
Table 1. Summary of CAP Update Measures and Actions
Primary Actions
Action E-3.3.a: Construct “solar carports” (also known as installing solar panels over outdoor parking spaces)
at eligible city-owned parking lots.
Supportive Actions
Action E-3.3.b: Conduct feasibility study for solar carport installation at city facilities to determine which are
eligible and for what size of system.
Action E-3.3.c: Seek grant funding and leverage partnerships to install solar carports.
Measure E-4: Residential Building Energy
Measure E-4.1: Residential Building Energy – Existing Reach Code
Primary Actions
Action E-4.1.a: Continue implementing existing building energy efficiency and water heater ordinances
(adopted in 2019).
Supportive Actions
Action E-4.1.b: Explore updating the Home Energy Score Assessment Pilot Program.
Action E-4.1.c: Leverage CEA and SDG&E customer programs, or other similar programs
Action E-4.1.d: Explore pilot programs and incentives to educate residents on energy efficiency and
renewable energy options for new and existing buildings.
Measure E-4.2: Residential Building Energy – Updated Reach Code
Primary Actions
Action E-4.2.a: Update city’s building code, or “reach code,” to include updated energy performance-based
requirements for new residential buildings.
Supportive Actions
Action E-4.2.b: Leverage CEA and SDG&E customer programs, or other similar programs.
Action E-4.2.c: Explore pilot programs and incentives to educate residents on energy efficiency and
renewable energy options for new and existing buildings
Measure E-5: Building Energy Benchmarking
Primary Actions
Action E-5.a: Develop, adopt, and implement a building energy benchmarking ordinance.
Supportive Actions
Action E-5.b: Prepare a building stock analysis.
Action E-5.c: Explore options and best practices for requiring existing commercial and residential buildings of
a certain size to submit energy data annually.
Action E-5.d: Conduct education and outreach to building owners and the public regarding new
requirements.
Measure E-6: Decarbonize Existing Buildings
Primary Actions
Action E-6.a: Reduce energy usage and decarbonize existing residential buildings, particularly existing
residential buildings not covered by any reach code requirements.
Supportive Actions
Action E-6.b: Explore updating the Home Energy Score Assessment Pilot Program.
Oct. 2, 2024 Item #1 32 of 157
Table 1. Summary of CAP Update Measures and Actions
Action E-6.c: Leverage CEA and SDG&E customer programs, or other similar programs.
Action E-6.d: Seek external funding to launch and/or leverage existing pilot programs and incentives to
support existing building decarbonization (e.g., appliance exchange, weatherization, solar PV installation,
battery storage)
Action E-6.e: Leverage building stock analysis (prepared for E-5) to target existing residential buildings.
Water and Wastewater
Measure W-1: Wastewater System Improvements
Primary Actions
Action W-1.a: Continue making improvements to the City of Carlsbad’s collection system, including but not
limited to upgrading lift stations.
Supportive Actions
Action W-1.b: Explore system improvements based on SCADA Master Plan.
Measure W-2: Water System Improvements
Primary Actions
Action W-2.a: Continue making improvements to CMWD’s potable and recycled water systems, including but not limited to expanding water reuse, and using renewable energy to power facilities.
Supportive Actions
Action W-2.b: Continue to explore local water supply options and assess feasibility and cost to benefit ratio.
Action W-2.c: Assess feasibility and seek funding for renewable energy and/or storage at CMWD facilities.
Waste Diversion
Measure WD-1: Solid and Organic Waste Diversion
Primary Actions
Action WD-1.a: Reduce waste disposal to 4.2 pounds per person per day (or the equivalent of a 75%
diversion rate) by 2035 and to 1.7per person per day (or the equivalent of a 90% diversion rate) by 2045.
Action WD-1.b: Divert 75% organic waste by 2035 and 90% by 2045.
Supportive Actions
Action WD-1.c: Research ordinance for requirement of a percentage of disposal for organic waste.
Action WD-1.d: Encourage maximum organics diversion from local businesses.
Action WD-1.e: Establish a Construction & Demolition diversion program.
Action WD-1.f: Maximize edible food recovery.
Action WD-1.g: Establish a program for permitted haulers for proper diversion of all waste streams.
Action WD-1.h: Continue implementing existing Sustainable Materials Management systems and ordinances
citywide, including at city facilities and events.
Action WD-1.i: Continue implementing existing compost and mulch giveaway programs; explore launching
new giveaway programs that target specific users.
Action WD-1.j: Update the city’s sustainable purchasing policy to include regulatory requirements for
sustainable procurement.
Action WD-1.k: Pursue vendor contracts to help implement diversion goals and monitor compliance.
Oct. 2, 2024 Item #1 33 of 157
Table 1. Summary of CAP Update Measures and Actions
Off-Road Equipment
Measure OR-1: Convert Gas-Powered Leaf Blowers
Primary Actions
Action OR-1.a: Develop, adopt, and implement an ordinance prohibiting the use of gas-powered leaf
blowers.
Supportive Actions
Action OR-1.b: Leverage existing State and regional resources to promote trade-in of existing gas-powered
leaf blowers or other similar incentives.
Action OR-1.c: Conduct outreach regarding the new requirements.
Measure OR-2: Increase Renewable or Alternative Fuel Construction Equipment
Primary Actions
Action OR-2.a: Develop, adopt, and implement an ordinance requiring new developments and significant
land-moving and construction projects to use electric-powered or alternatively-fueled construction
equipment that reduces 50% of emissions from project construction activities.
Supportive Actions
Action OR-2.b: Exempt small residential and non-residential projects from this requirement.
Action OR-2.c: Conduct outreach regarding new requirements.
Action OR-2.d: Seek external funding and leverage existing resources to support conversion of medium and
heavy duty vehicles.
Carbon Sequestration
Measure CS-1: Community Forest Management
Primary Actions
Action CS-1.a: Increase city’s tree inventory by continuing to implement the Community Forest Management
Plan.
Action CS-1.b: To help sustain the city’s tree inventory, continue replacing trees at a 2:1 ratio.
Action CS-1.c: Conduct an inventory to assess urban canopy cover every five years.
Supportive Actions
Action CS-1.d: Explore additional locations for tree planting beyond what is included in the Community
Forest Management Plan, with “right tree right space,” ongoing budget, and maintenance costs taken into
consideration.
Action CS-1.e: Encourage eligible residents to take part in a free street tree planting assessment.
Source: City of Carlsbad 2024.
Note: The implementation actions under each GHG reduction measure have been categorized as “Primary” or
“Supportive” to signify the degree in which an action affects the quantifiable GHG reductions that are expected
to be achieved with implementation. Primary actions are implementation actions that drive quantifiable GHG
reductions. Supportive actions provide additional support to the successful implementation of the measure and
may also have associated GHG reductions that have not been quantified as part of the CAP Update.
The city has developed an update to its Climate Action Plan Consistency Review Checklist (CAP
Oct. 2, 2024 Item #1 34 of 157
Consistency Checklist), in conjunction with the CAP Update, to provide a streamlined review process
for proposed new development projects that are subject to discretionary review and trigger
environmental review pursuant to CEQA. New developments that are consistent with growth
projections and applicable GHG reduction measures of the CAP Update are eligible for streamlining
under State CEQA Guidelines Section 15183.5. The proposed CAP Consistency Checklist is discussed in
more detail in Chapter 4 of the CAP update.
The CAP Update includes strategies, measures, and actions intended to reduce GHG emissions from
six emissions sectors. To achieve reductions in GHG emissions, measures and actions within each
sector are proposed to be implemented within specific timeframes. The strategies, measures, and
actions are listed in full in Table 1. The strategies, measures, and actions describe the overall approach
and detail the specific programs and actions that the city will carry out. This Addendum has been
prepared to address the implementation of the CAP Update measures and actions that could result in
reasonably foreseeable physical impacts to the environment. More focused CEQA analysis (focusing
on specifics of individual implementing actions) may be required in the future.
Discretionary Actions
The CAP Update would require the following discretionary actions by the City Council:
• Approval of Addendum No. 1 to the Housing Element Implementation and Public Safety
Element Update Supplemental Environmental Impact Report
• Adoption of the CAP Update
Location of Prior Environmental Document(s)
The location and custodian of the General Plan update EIR, and Housing Element Implementation and
Public Safety Element Update SEIR are the City Clerk, City of Carlsbad, 1200 Carlsbad Village Drive,
Carlsbad, CA. A copy of the previous environmental documents is also available online at the City of
Carlsbad, Planning Department website:
https://www.carlsbadca.gov/home/showpublisheddocument/14316/638248571137030000
Oct. 2, 2024 Item #1 35 of 157
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Oct. 2, 2024 Item #1 36 of 157
2 Project Context
The following provides a history and timeline of the environmental documentation that has been
prepared for the City of Carlsbad’s CAP and Housing Element Implementation and Public Safety
Element Update.
On September 22, 2015, the City of Carlsbad certified a final environmental impact report (EIR) for a
comprehensive update to the General Plan and a Climate Action Plan (General Plan & Climate Action
Plan Environmental Impact Report, State Clearinghouse Number 2011011004, dated June 2015) (City
of Carlsbad 2015). The city’s 2015 CAP was developed in response to AB 32, and the increasing severity
of climate events. The 2015 CAP includes goals, policies, and actions for Carlsbad to reduce GHG
emissions and address climate change through 2035. The certified EIR discussed the potential
environmental impacts (both direct and indirect impacts) associated with future development allowed
under the General Plan update and included a thorough analysis of the estimated build out of the city
through the horizon year 2035. The EIR found that, with implementation of the policies and programs
contained in the General Plan and recommended mitigation measures, all impacts (direct and indirect)
associated with future development under the General Plan update would be less than significant,
except impacts on Air Quality and Transportation which would be significant and unavoidable.
As statewide targets adjusted to limit global warming below 2 degrees Celsius, the city has adapted its
CAP and GHG reduction targets accordingly. On July 14, 2020, the City Council approved CAP
Amendment No. 1 to revise the GHG inventory and reduction targets and forecast, update reductions
from existing measures and incorporate community choice energy as a new reduction measure. This
was partially influenced by the publication of the 2017 California Air Resources Board (CARB) Climate
Change Scoping Plan (Scoping Plan) and the 2018 San Diego Association of Governments (SANDAG)
Regional Climate Action Planning Framework (ReCAP). Both documents included new guidance on
calculating GHG reduction targets. The amended CAP contained a 2012 GHG inventory, requiring the
recalculation of 2020 and 2035 emissions reduction targets and recalculation of the business-as-usual
(BAU) forecast, State and federal emissions reductions, and local reductions needed to reach a 2017
Scoping Plan aligned target. The BAU forecast assumes no additional actions to reduce GHG emissions
occur after 2012 (the updated baseline inventory year), providing an assessment of how Carlsbad’s
GHG emissions would change with future growth.
Addendum No. 1 to the 2015 General Plan Update and CAP EIR was prepared in May 2020 for updates
to the certified CAP (“CAP Amendment No. 1”) (City of Carlsbad 2020). CAP Amendment No. 1 included
use of the 2012 GHG inventory, calculation of 2020 and 2035 targets using the 2012 GHG inventory and
guidance from CARB’s 2017 Climate Change Scoping Plan, the addition of Community Choice Energy
(CCE) as a GHG reduction measure and recalculation of the CAP measures to reflect changes in State
and federal policies and the changed electrical generation emissions factor associated with CCE. The
Addendum concluded that CAP Amendment No. 1 did not constitute a substantial change in the project
or circumstances involving significant environmental effects or a substantial increase in the severity of
previously identified effects. The mitigation measures previously included and remaining in the CAP,
and the CCE implementation measure remained feasible. Therefore, CAP Amendment No. 1 did not
necessitate a subsequent EIR because it did not create any of the situations contained in State CEQA
Guidelines Section 15162.
Oct. 2, 2024 Item #1 37 of 157
The Housing Element Update for the General Plan was prepared in late 2020 and provided to the
California Department of Housing and Community Development (HCD) for preliminary review. The
Housing Element was analyzed under its own respective CEQA document, Addendum No. 2 to the
2015 General Plan EIR, which was approved by the City Council on April 6, 2021 (SCH#2011011004)
(City of Carlsbad 2021). This Addendum found that, with implementation of mitigation measures, all
impacts (direct and indirect) associated with the Housing Element did not identify any changes in the
Project (2015 General Plan), changes in circumstance, and/or any new information of substantial
importance that would cause significant effects to environmental resources. Addendum No. 2
determined that the 2015 General Plan EIR was of continuing informational value, the changes in the
2021 Housing Element Update were within the scope of that previously certified EIR, and none of the
conditions requiring the preparation of subsequent or supplemental environmental review under
CEQA Guidelines section 15162 existed.
On February 2, 2024, the City of Carlsbad certified a supplemental environmental impact report (SEIR)
which consists of amendments to the Carlsbad General Plan, including the Land Use and Community
Design Element and Public Safety Element, and amendments to Carlsbad Municipal Code Title 21, the
Zoning Ordinance (Housing Element Implementation and Public Safety Element Update Supplemental
Environmental Impact Report, State Clearinghouse Number 2022090339, dated July 2023) (City of
Carlsbad 2024). The certified SEIR discussed the potential environmental impacts (both direct and
indirect impacts) associated with the development of housing on 18 sites as part of the Housing Element
implementation. The SEIR identified updates to the Carlsbad General Plan, specifically the Land Use and
Community Design Element, to allow for this development. The Public Safety Element would also be
updated to ensure consistency with State regulations. Updates to the Land Use and Community Design
Element included the addition of two new residential land use designations (R-35 and R-40) for the
accommodation of higher density residential development, establishment of revised minimum
densities for some residential designations, miscellaneous, related changes to tables, text and policies,
and changes to land use designations on multiple sites to accommodate the city’s Regional Housing
Needs Allocation (RHNA) share. Updates to the Public Safety Element included the addition of the
requirements of new State legislation and the incorporation of new policies based on local and regional
data. The SEIR found that, with implementation of mitigation measures, all impacts (direct and indirect)
associated with the Housing Element Implementation and Public Safety Element Update would be less
than significant, except impacts on Air Quality, GHG, Noise, and Transportation which would be
significant and unavoidable.
In considering the potential environmental impacts of the CAP Update, the city has determined that
the EIR certified for the 2015 General Plan update and SEIR certified for the 2024 Housing Element
Implementation and Public Safety Element Update are of continuing informational value. The city also
has determined that the potential environmental impacts (both direct and indirect impacts) of the CAP
Update are within the scope of the previously certified EIR and SEIR and that none of the conditions
requiring subsequent or supplemental environmental review under CEQA Guidelines section 15162
exists. Based on the information and analysis provided below, the city has determined that only minor
or technical changes to the previously certified EIR are necessary and that that preparation of an
Addendum pursuant to CEQA Guidelines section 15164 is appropriate.
Oct. 2, 2024 Item #1 38 of 157
3 Overview of the CEQA Guidelines
Section 15160 of the CEQA Guidelines explains that there are several mechanisms, and variations in
environmental documents, that can be tailored to different situations and intended uses of
environmental review. Specifically, Section 15160 states that the “…variations listed [including
Subsequent EIRs, Supplemental EIRs, and Addendums] are not exclusive. Lead agencies may use other
variations consistent with the Guidelines to meet the needs of other circumstances.” This provision
allows Lead agencies to tailor the use of CEQA mechanisms (such as this Addendum) to fit the
circumstances presented to the Lead agency by a project. Here, the city has opted to prepare an
Addendum to assess the minor modifications of the Project that have transpired since preparation of
the EIR.
Public Resources Code Section 21166 and California Environmental Quality Act (CEQA) Guidelines
Sections 15162 and 15164 set forth the criteria for determining the appropriate additional
environmental documentation, if any, to be completed when changes are proposed to a project that
has a previously certified Environmental Impact Report (EIR). When considering the need for
additional environmental review, the fundamental determination a lead agency must make is whether
the previously certified EIR retains some informational value or whether changes in the project or
circumstances have rendered it wholly irrelevant. If the previously certified EIR has continuing
informational value, the lead agency then must determine whether the proposed changes in the
Project require additional environmental review under Public Resources Code Section 21166 and
CEQA Guidelines Section 15162.
CEQA Guidelines Section 15164 states that a lead agency shall prepare an addendum to a previously
certified EIR if some changes or additions are necessary, but none of the conditions described in
Section 15162 calling for preparation of a subsequent EIR have occurred. CEQA Guidelines section
15162(a) states that no Subsequent or Supplemental EIR shall be prepared for a project with a certified
EIR unless the lead agency determines, based on substantial evidence in the light of the whole record,
one or more of the following:
1.Substantial changes are proposed in the project that will require major revisions of the previous
EIR due to the involvement of new significant environmental effects or a substantial increase in
the severity of previously identified significant effects.
2.Substantial changes occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR due to the involvement of new
significant environmental effects or a substantial increase in the severity of previously identified
significant effects.
3.New information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified as
complete, shows any of the following:
A.The project will have one or more significant effects not discussed in the previous EIR.
B.Significant effects previously examined will be substantially more severe than shown in the
previous EIR.
C.Mitigation measures or alternatives previously found not to be feasible would in fact be
feasible and would substantially reduce one or more significant effects of the project, but the
project proponents decline to adopt the mitigation measure or alternative.
Oct. 2, 2024 Item #1 39 of 157
D. Mitigation measures or alternatives that are considerably different from those analyzed in
the previous EIR would substantially reduce one or more significant effects on the
environment, but the project proponents decline to adopt the mitigation measure or
alternative.
The analysis pursuant to Section 15162 demonstrates whether the lead agency can approve the activity
as being within the scope of the existing certified EIR, that an addendum to the existing EIR would be
appropriate, and no new environmental document, such as a new EIR, would be required. The addendum
need not be circulated for public review but can be included in or attached to the final EIR, and the
decision-making body shall consider the addendum with the final EIR prior to deciding on the project.
The City of Carlsbad has prepared this Addendum, pursuant to CEQA Guidelines Sections 15162 and
15164, to evaluate whether the Project’s environmental impacts are covered by and within the scope
of the Housing Element Implementation and Public Safety Element Update Supplemental
Environmental Impact Report (State Clearinghouse Number 2022090339, dated July 2023). The
following Addendum details any changes in the Project, changes in circumstances under which the
Project is undertaken, and/or “new information of substantial importance” that may cause one or
more significant effects to environmental resources.
The responses herein substantiate and support the City of Carlsbad’s determination that the potential
environmental impacts of the CAP Update measures and actions are within the scope of the Housing
Element Implementation and Public Safety Element Update SEIR, do not require subsequent or
supplemental environmental review under CEQA Guidelines Section 15162 and, in conjunction with
the SEIR, preparation of an Addendum pursuant to CEQA Guidelines Section 15164 is appropriate.
Oct. 2, 2024 Item #1 40 of 157
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5 Addendum Methodology
The city has previously prepared and certified an EIR for the 2015 General Plan, an Addendum for the
CAP Amendment (2020), an Addendum for the Housing Element (2021), and a SEIR for the Housing
Element Implementation and Public Safety Element Update (2024). Collectively, these CEQA reviews
are known as the “Previous CEQA Documents.” No legal actions were filed challenging the Previous
CEQA Documents and thus are presumed valid.
Since the adoption of the Previous CEQA Documents, there have been no substantial changes in the
city’s policies that relate to actions in the CAP Update; neither has there been new information, or a
change of circumstances which would invalidate the Previous CEQA Documents. In addition, the city
adopted ordinances in 2019 that amended the Carlsbad Municipal Code related to energy efficiency,
renewable energy, alternative water heating, electric vehicle charging infrastructure and
transportation demand management, which further mitigate environmental impacts.
The CAP Update is a programmatic planning document which catalogues the priorities of the city for
reducing energy use and greenhouse gas emissions to meet State reduction targets. The CAP Update
does not approve or authorize a project that could potentially alter the environment. Rather, it
outlines the need for future work to advance each of the separate measures and actions.
Oct. 2, 2024 Item #1 42 of 157
6 Addendum Evaluation
Aesthetics
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions Described in
§15162 Occur?
(§15164(a))
Project is within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Have a substantial adverse effect
on a scenic vista?
Less than
Significant None No No No Yes Yes
b. Substantially damage scenic
resources, including, but not
limited to, trees, rock
outcroppings, and historic
buildings within a State scenic
highway?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 43 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the
Proposed
Changes
Involve a New
or Substantial Increase in
the Severity
of Previously
Identified
Impacts?
Are There New
Circumstances Involving a
New or Substantial Increase
in the Severity of Previously
Identified Impacts?
Is There New
Information
of Substantial Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of the
SEIR?
c. In non-urbanized areas, substantially
degrade the exiting visual character or
quality of public views of the site and its
surroundings (Public views are those
that are experienced from publicly
accessible vantage point). If the project
is in an urbanized area, would the
project conflict with applicable zoning
and other regulations governing scenic
quality?
Less than Significant None No No No Yes Yes
d. Create a new source of substantial light or
glare that would adversely affect day- or
nighttime views in the area?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 44 of 157
Previous CEQA Analysis Aesthetics Findings
The 2024 SEIR identified less than significant impacts for scenic vistas (AES-1), scenic resources within
scenic highways (AES-2), visual quality (AES-3), and light and glare (AES-4) (Section 4.1, Aesthetics).
Addendum Analysis
The implementation of the CAP Update measures and actions would result in short-term and long-
term changes related to aesthetics as described below.
Construction activities associated with the implementation of the CAP Update, such as equipment use
and staging of materials, would result in short-term, temporary changes to aesthetic conditions in the
city. The types of construction activities associated with the CAP Update would vary depending on the
type of CAP Update measure. For example, Measures T-1, T-4, T-5, T-8, and T-9 would involve removing
existing pavement; repaving roadway surfaces; painting or restriping pavement; modifying curbs; laying
concrete, and installing traffic signals, lighting, landscaping, street furniture, and other amenities. Some
of these improvements, such as Measure E-3.3, W-1, and W-2, would require limited ground
disturbance. Construction activities would be short-term and temporary, and would not involve
equipment of substantial height, bulk, or massing that would have substantial adverse effects on existing
scenic vistas, scenic resources, or visual quality. Because duration of these activities would be limited to
relatively short periods, their temporary effects on aesthetic resources would not be substantial.
Construction activities would also incrementally increase sources of light and glare in the city, for
example from outdoor lighting sources associated with construction of transportation improvements
and glare from construction vehicles and equipment. Construction activities would generally occur
during daytime hours and would comply with applicable lighting requirements including the City’s
Zoning Ordinance and Title 24 of the California Building Code that reduce light spillover. Furthermore,
construction activities would be located in developed areas with existing sources of outdoor lighting
and glare, characteristic of developed urban and suburban environments. Thus, the CAP Update would
not create temporary new sources of substantial light or glare that would adversely affect day or
nighttime views in the city.
Long-term changes resulting from implementation of CAP Update measures would include
improvements at or near grade level of existing roadways, as well as minor changes to traffic
intersections and walkways (through implementation of Measures T-1, T-4, T-5, T-8, and T-9),
improvements to water and wastewater systems (Measures W-1 and W-2), and planting of trees
(through implementation of Measure CS-1). Energy-related measures such as Measure E.3-3, which
includes the construction of solar carports, would also result in changes to the aesthetic environment.
Implementation of Measures T-1, T-4, T-5, T-8, and T-9 would also result in the installation of new
sidewalks, new and upgraded bikeways and walkways along existing developed roadways and rights-
of-way in the city, and the installation of roundabouts or control traffic within the intersections of
existing developed roadways. The CAP Update would not result in new features of substantial height,
bulk, or massing that would result in substantial long-term damage to scenic vistas, scenic resources,
or visual quality. Additionally, the increase in planted trees and the development of new landscaping
(Measure CS-1) would offer long-term visual improvement to the local surrounding area and would
not result in a substantial effect to scenic vistas, scenic resources, or visual quality.
Transportation measures and actions included in the CAP Update would include improvements to the
city’s existing pedestrian, bicycle, and transit network that may introduce new short term light
sources. In addition, installation of solar carports (Measure E-3.3) would introduce new sources of
glare from sunlight reflecting off of solar photovoltaic panels.
Oct. 2, 2024 Item #1 45 of 157
These types of improvements would comply with applicable lighting requirements including the city’s
Zoning Ordinance and Title 24 of the California Building Code that reduce light spillover. Improvements
resulting from implementation of the CAP Update would be located in developed areas with existing
sources of outdoor lighting and glare, characteristic of developed urban and suburban environments.
Thus, the CAP Update would not create new long-term sources of substantial light or glare that would
adversely affect day or nighttime views in the city.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to aesthetics. The 2024 SEIR did not identify
significant aesthetic impacts and did not identify mitigation measures. The CAP Update would not
result in any new or substantially more severe significant impacts related to aesthetics. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to
aesthetics.
Oct. 2, 2024 Item #1 46 of 157
Agriculture and Forestry Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Convert Prime Farmland, Unique
Farmland, or Farmland of
statewide Importance, as shown
on maps prepared pursuant to
the Farmland Mapping and
Monitoring Program of the
California Resources Agency, to
nonagricultural use?
No Impact None No No No Yes Yes
b. Conflict with existing zoning for
agricultural use, or a Williamson
Act contract?
No Impact None No No No Yes Yes
Oct. 2, 2024 Item #1 47 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the
Proposed
Changes
Involve a New
or Substantial Increase in
the Severity
of Previously
Identified
Impacts?
Are There New Circumstances
Involving a New or
Substantial Increase in the
Severity of Previously
Identified Impacts?
Is There New
Information of Substantial
Importance
Requiring New
Analysis or
Verification?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did None of
the Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
c. Conflict with existing zoning for, or
cause rezoning of, forest land, as
defined in Public Resources Code
Section 12220 (g)), timberland (as
defined by Public Resources Code
Section 4526), or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?
No Impact None No No No Yes Yes
d. Result in the loss of forest land or
conversion of forest land to non-forest
use?
No Impact None No No No Yes Yes
e. Involve other changes in the exiting
environment which, due to their
location or nature, could result in the
conversion of Farmland, to non-
agricultural use or conversion of forest
land to non-forest use?
No Impact None No No No Yes Yes
Oct. 2, 2024 Item #1 48 of 157
Previous CEQA Analysis Agriculture and Forestry Resources Findings
The 2024 SEIR identified no impacts for converting Prime Farmland, Unique Farmland, or Farmland of
Statewide Importance (Farmland); for conflicting with existing zoning for agricultural use or a
Williamson Act contract or with existing zoning for, or cause rezoning of, forest land (as defined in
Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section
4526); or timberland zoned Timberland Production (as defined by Government Code Section
51104(g)); and for resulting in the loss of forest land or conversion of forest land to non-forest use; or
involving other changes in the existing environment which, due to their location or nature, could result
in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use
(Section 4.16.1, Agriculture and Forestry Resources).
Addendum Analysis
Implementation of the CAP Update would not result in the conversion of Important Farmland or forest
land to urban or other uses. Measures and actions included in the CAP Update may include
construction activities, such as equipment use and staging of materials; however, construction
activities would occur in previously disturbed, developed areas not currently used for agricultural uses
or under a Williamson Act contract. There are currently no Williamson Act contracts in the city and the
CAP Update does not propose land use changes that would affect the status of any Williamson Act
contracts (DOC 2024). Additionally, there are no areas in the city zoned as forest or timberland,
therefore, implementation of the CAP Update would not conflict with existing zoning or cause rezoning
any forest land, timberland, or timber land zoned for timberland production. Therefore, the CAP
Update would not involve other changes in the exiting environment which, due to their location or
nature, could result in the conversion of Farmland, to non-agricultural use or conversion of forest land
to non-forest use.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to agriculture and forestry resources. The 2024
SEIR did not identify significant agriculture and forestry resources impacts and did not identify
mitigation measures. The CAP Update would not result in any new or substantially more severe
significant impacts related to agriculture and forestry resources. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to
agriculture and forestry resources.
Oct. 2, 2024 Item #1 49 of 157
Air Quality
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a.Conflict with or obstruct
implementation of the applicable
air quality plan?
Less than
Significant with
Mitigation
MM AQ-1 No No No Yes Yes
b.Result in a cumulatively
considerable net increase of any
criteria pollutant for which the
project region is non-attainment
under an applicable federal or
State ambient air quality
standard?
Significant and
Unavoidable MM AQ-2 No No No Yes Yes
c.Expose sensitive receptors to
substantial pollutant
concentrations?
Less than
Significant with
Mitigation
MM AQ-3
MM AQ-4 No No No Yes Yes
d.Result in other emissions (such as
those leading to odors) adverselyaffecting a substantial number of
people?
Less than Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 50 of 157
Previous CEQA Analysis Air Quality Findings
The 2024 SEIR identified a less than significant impact related to a conflict with or obstruction of the
San Diego Regional Air Quality Strategy or State Implementation Plan (AQ-1) with implementation of
mitigation measure AQ-1. The 2024 SEIR identified that although mitigation measure AQ-2 would
reduce operational emissions from future development, it would be speculative to quantify such
emissions until details of the individual projects are known and concluded impacts to be significant
and unavoidable (AQ-2). The 2024 SEIR identified a less than significant impact related to exposing
offsite sensitive receptors to substantial pollution concentrations (AQ-3) with implementation of
mitigation measure AQ-3 and mitigation measure AQ-4. The 2024 SEIR also identified a less than
significant impact related to creating objectional odors (AQ-4) (Section 4.2, Air Quality).
Addendum Analysis
The implementation of the CAP Update measures and actions would result in short-term and long-
term changes related to air quality as described below.
Construction activities associated with the implementation of the CAP Update, such as equipment use,
construction of new facilities or retrofitting of existing facilities, would result in construction-related
air quality emissions. The types of construction activities associated with the CAP Update would vary
depending on the type of CAP Update measure. Examples of activities that would result from
implementation of the CAP Update measures include construction of new EV charging stations, public
zero emission vehicle and bicycle charging infrastructure, building efficiency retrofits, roundabouts or
traffic circles, new and improved bicycle infrastructure, new solar carports, and water and wastewater
system improvements (e.g., Measures T-1, T-2, T-3, T-4, T-5, T-8, T-9, E-3.3, W-1, and W-2). These
construction activities would involve using construction equipment and vehicles to remove existing
pavement; repave roadway surfaces; paint or restripe pavement; modify curbs; lay concrete, and
install traffic signals, lighting, landscaping, street furniture, and other amenities. These construction
activities would be completed by workers located in the city and surrounding areas in the San Diego
region.
Construction activities resulting from implementation of the CAP Update would generate emissions of
ROG, NOX, PM10, and PM2.5 associated with off-road equipment use (i.e. excavators, front loaders,
pavers, dump trucks, cranes, and backhoes), material and equipment delivery trips, worker commute
trips, and other miscellaneous activities. Construction activities would be relatively small in scale,
occur intermittently in different locations throughout the city, last for only short periods of time, and
would not require substantial relocation of construction workers from areas outside of the city and
the San Diego region. The CAP Update includes measures that would reduce air pollutant emissions
during construction activities. For example, measure OR-2 would increase the use of renewable and
alternative fuel construction equipment, while Measure T-9 would establish city fleet regulations for
idling, thus reducing construction vehicle idling time and further reducing construction related air
pollutant emissions. Due to the non-intensive, sporadic, and dispersed nature of these construction
activities, emissions of criteria air pollutants would not occur in concentrations which would exceed
SDAPCD thresholds and would therefore be consistent with the goals of the San Diego Regional Air
Quality Strategy or State Implementation Plan. Therefore, mitigation measure AQ-1 identified in the
SEIR would not apply to the construction related air pollutant emissions of the CAP Update. Mitigation
measure AQ-1 identified in the SEIR applies specifically to the construction impacts associated with
housing development projects permitted under implementation of the Housing Element Update, and
would therefore not apply to the CAP Update.
Oct. 2, 2024 Item #1 51 of 157
The CAP Update includes several measures (T-4, T-5) that would reduce GHG and vehicle miles
traveled (VMT) through the expansion of bicycle infrastructure, and increased connectivity of sidewalk
networks. Although there would be a temporary, nominal amount of vehicle trips related to
construction worker commute and equipment delivery associated with bike and sidewalk
improvements and other construction activities resulting from CAP Update implementation, the CAP
Update would not result in result in a cumulatively considerable net increase of any criteria pollutant
for which the project region is non-attainment under an applicable federal or State ambient air quality
standard. Therefore, mitigation measure AQ-2 identified in the SEIR would not apply to the CAP
Update.
Measures that would result in new zero emission vehicle and bicycle charging stations (T-8),
roundabouts (T-1), improved bicycle infrastructure (T-4), solar carports (E-3.3) would result in minor
criteria air pollutant and TAC emissions during construction. It is unlikely that these types of activities
would be of the size, intensity, or duration to exceed SDAPCD thresholds of significance or to emit
substantial TAC concentrations. Measure WD-1 would increase the diversion of solid and organic
waste from landfills which could lead to increased haul truck trips to and from composting and
recycling facilities; however, it is anticipated that these trips would displace the haul truck trips that
would be diverted from the landfill. A substantial net increase in the number of haul truck trips and
associated criteria air pollutant emissions within the city would not be anticipated. Furthermore, these
haul truck trips would likely be infrequent and would not involve the trucks idling for extended periods
of time near sensitive receptors. As such, implementation of the CAP Update would not expose off-
site sensitive receptors to substantial pollution concentrations. Therefore, mitigation measures AQ-3
and AQ-4 identified in the SEIR would not apply to the CAP Update.
Construction activities that would occur under CAP Update implementation would result in temporary
generation of odorous emissions. However, consistent with the less than significant impact
determination of the 2024 SEIR, given the temporary and intermittent nature of the impacts, and
dissipation of odor, construction-related odor impacts would be minor. Furthermore, construction
activities would be required to comply with SDAPCD Rule 51 (Nuisance), which regulates nuisance
odors (SDAPCD 1976).
Long-term changes resulting from implementation of the CAP Update would reduce GHG emissions
generated within the city by implementing numerous transportation-, water-, waste-, and energy-
related measures. For example, the implementation of the CAP Update would encourage the use of
alternatively fueled vehicles through measures such as Measure T-8 which would involve installing and
incentivizing public zero emission vehicle and bicycle infrastructure. This would reduce overall gasoline
and fuel consumption, therefore reducing air pollutant emissions related to fossil fuel combustion.
Other transportation-related measures such as Measures T-5, T-7, and T-10 would reduce VMT in the
city by improving street connectivity, provide resources and incentives for alternative commutes, such
as a carpool matching, and implement parking management strategies. Reducing VMT would reduce
the emission of air pollutants by decreasing the consumption of fossil fuel in vehicles and reducing
emissions related to tire and brake wear.
Actions aimed at diverting and eliminating solid waste from disposal in landfills would generate
compostable materials and demand for compost products (e.g., Measure WD-1), which would lead to a
need for haul trucks to transport these materials. Truck trips for hauling of organic waste to processing
facilities would be offset by reductions in truck trips to landfills. Organic waste collected in the city is
recycled at a Republic Services composting facility in Otay (City of Carlsbad 2024).
Oct. 2, 2024 Item #1 52 of 157
Energy-related measures such as Measure E-3.1 would continue to implement and enforce the city’s
reach code which is focused on requiring solar photovoltaic (PV) and other energy efficiency measures
for new and existing nonresidential buildings, while Measure E-3.3 focuses on the installation of solar
carports at city-owned parking lots. While these reduction measures were formulated to reduce GHGs,
they would also improve overall air quality by reducing the emission of criteria air pollutants. A higher
proportion of buildings powered by more efficient and/or renewable electric systems due to
implementation of Measure E-3.1 would reduce natural gas combustion at nonresidential land uses
within the city, which would also reduce local criteria air pollution. The effects associated with the
reduction of air pollutant emissions in the city and SDAPCD would be largely beneficial and would, by
nature, reduce the concentration of air pollutants. Therefore, operational activities under
implementation of the CAP Update would not result in the exceedance of SDAPCD thresholds and
would be considered consistent with the goals of the San Diego Regional Air Quality Strategy or State
Implementation Plan. Operational activities would also not violate air quality standards or contribute
to an existing air quality violation because project-related emissions would not exceed SDAPCD
thresholds or result in a cumulatively considerable net increase of criteria pollutants for which the
region is nonattainment under applicable federal or State ambient air quality standards.
The operation of the measures and actions in the CAP Update would not expose off-site sensitive
receptors to substantial pollution concentrations. Measure WD-1 would result in increased odors from
the anaerobic decomposition of composted waste and haul truck trips to composting facilities. These
impacts would be avoided through implementation of an Odor Impact Minimization Plan (OIMP) as
required by State regulation. Therefore, the CAP Update would not result in new emissions (such as
those leading to odors) adversely affecting a substantial number of people.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to air quality. Implementation of mitigation
measures AQ-1 through AQ-4 from the SEIR are not applicable to the air quality impacts of the CAP
Update. The CAP Update would not result in any new or substantially more severe significant impacts
related to air quality. Applicable Mitigation Measures from the SEIR
The SEIR identified mitigation measures AQ-1 through AQ-4 for air quality impacts. None of these
mitigation measures are applicable to the CAP Update.
Oct. 2, 2024 Item #1 53 of 157
Biological Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Have a substantial adverse effect,
either directly or through habitat
modifications, on any species
identified as a candidate,
sensitive, or special status species
in local or regional plans, policies,
or regulations, or by the California
Department of Fish and Wildlife or
US Fish and Wildlife Service?
Less than
Significant
with
Mitigation
MM BIO-1
MM BIO-2 No No No Yes Yes
b. Have a substantial adverse effect
on any riparian habitat or other
sensitive natural community
identified in local or regional
plans, policies, or regulations, or
by the California Department of
Fish and Wildlife or US Fish and
Wildlife Service?
Less than
Significant
with
Mitigation
MM BIO-1
MM BIO-3
MM BIO-4
No No No Yes Yes
Oct. 2, 2024 Item #1 54 of 157
CEQA Guidelines Section 15162 Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed Changes Involve a New or Substantial
Increase in the Severity of Previously
Identified
Impacts?
Are There New Circumstances Involving a New or Substantial
Increase in the Severity of Previously
Identified
Impacts?
Is There New Information of Substantial
Importance Requiring New Analysis
or
Verification?
Are Only Minor Technical Changes or Additions Necessary or Did
None of the Conditions Described in
§15162 Occur?
(§15164(a))
Project is within the
Scope of
the SEIR?
c. Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Less than
Significant
with Mitigation
MM BIO-1
MM BIO-3
MM BIO-4 MM BIO-5
No No No Yes Yes
d. Interfere substantially with the movement of any native resident
or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of
native wildlife nursery sites?
Less than Significant with
Mitigation
MM BIO-1 MM BIO-3 MM BIO-4 No No No Yes Yes
e. Conflict with any local policies or
ordinances protecting biological resources, such as a tree
preservation policy or ordinance?
Less than Significant with
Mitigation
MM BIO-6 No No No Yes Yes
f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
Less than
Significant with Mitigation
MM BIO-1
MM BIO-2
MM BIO-3 MM BIO-4 MM BIO-7
MM BIO-8
No No No Yes Yes
Oct. 2, 2024 Item #1 55 of 157
Previous CEQA Analysis Biological Resources Findings
The 2024 SEIR identified a less than significant impact related to a substantial adverse effect, either
directly or through habitat modifications, on any species identified as a candidate, sensitive, or special
status species in local or regional plans, policies, or regulations, or by the California Department of Fish
and Wildlife or US Fish and Wildlife Service (BIO-1) with implementation of mitigation measures BIO-
1 and BIO-2. The 2024 SEIR identified a less than significant impact to any riparian habitat or other
sensitive natural community identified in local or regional plans, policies, regulations or by the
California Department of Fish and Wildlife or US Fish and Wildlife Service (BIO-2) with implementation
of mitigation measures BIO-1, BIO-3, and BIO-4. The 2024 SEIR identified a less than significant impact
to State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.)
(BIO-3) with implementation of mitigation measures BIO-1, BIO-3, BIO-4, and BIO-5. The 2024 SEIR
identified a less than significant impact to interfering substantially with the movement of any native
resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impeding the use of native wildlife nursery sites (BIO-4) with implementation of
mitigation measures BIO-1, BIO-3, and BIO-4. The 2024 SEIR identified a less than significant impact
related to conflicts with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance (BIO-5) with implementation of mitigation measure BIO-6. The 2024
SEIR identified a less than significant impact related to conflicts with the provisions of an adopted
Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional,
or State habitat conservation plan (BIO-6) with implementation of mitigation measures BIO-1, BIO-2,
BIO-3, BIO-4, BIO-7 and BIO-8 (Section 4.3, Biological Resources).
Addendum Analysis
Implementation of the CAP Update would include measures and actions that involve construction and
ground disturbing activities, including minor grading and excavation. For example, Measures T-1, T-4, T-
5, T-8, and T-9 would involve removing existing pavement; repaving roadway surfaces; painting or
restriping pavement; modifying curbs; laying concrete, and installing traffic signals, lighting, landscaping,
and trees. Some of these improvements, such as Measures E-3.3, W-1, and W-2, would require limited
ground disturbance from construction activities. The CAP Update consists of minor improvements and
building retrofits within the city and construction activities would occur in previously disturbed,
developed areas such as roadways and parking lots that lack natural habitat and where candidate,
sensitive, or special-status species or their habitats are not present. Therefore, implementation of the
CAP Update would not cause a substantial adverse direct or indirect effect to special-status species.
Because implementation of the CAP Update would occur in previously disturbed, developed areas,
implementation of the CAP Update would not occur in areas where riparian habitat or other sensitive
natural communities, protected wetlands, wildlife corridors, and protected biological resources are
present. Furthermore, implementation of mitigation measure BIO-2 would reduce any impacts to
candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or US Fish and Wildlife Service because the pre-construction
bird surveys would ensure that active nests are identified and as necessary avoided. Implementation of
mitigation measure BIO-2 would also reduce conflicts with the city’s Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or State habitat conservation plans
because it would assure compliance with the Migratory Bird Treaty Act (MBTA) and California Fish and
Game Code (CFGC) Section 3503. Implementation of mitigation measure BIO-6 would reduce any
conflicts with any local policies or ordinances protecting biological resources, such as a tree preservation
policy or ordinance because it would require a project-specific tree survey to determine measures to
address impacts such as avoidance, minimization, restoration, or compensation.
Oct. 2, 2024 Item #1 56 of 157
Because duration of construction activities would be limited to relatively short periods, their
temporary effects on biological resources would not be substantial.
Long-term changes resulting from implementation of CAP Update measures would include
improvements at or near grade level of existing roadways, as well as minor changes to traffic
intersections and walkways (through implementation of Measures T-1, T-4, T-5, T-8, and T-9),
improvements to water and wastewater systems (Measures W-1 and W-2), planting of trees (through
implementation of Measure CS-1). Implementation of Measures T-1, T-4, T-5, T-8, and T-9 would also
result in the installation of new sidewalks, new and upgraded bikeways and walkways along existing
developed roadways and rights-of-way in the city, and the installation of roundabouts or control traffic
within the intersections of existing developed roadways. The CAP Update would not result in physical
improvements or effects that would result in substantial long-term damage to biological resources.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to biological resources. Implementation of
mitigation measures BIO-1, BIO-3, BIO-4, BIO-5, BIO-7, and BIO-8 from the SEIR are not applicable to
the CAP Update. Implementation of mitigation measure BIO-2 would ensure a less-than-significant
impact to special-status biological resources. Implementation of mitigation measure BIO-6 would
ensure a less-than-significant impact for conflict with any local policies or ordinances protecting
biological resources, such as a tree preservation policy or ordinance. The CAP Update would not result
in any new or substantially more severe significant impacts related to biological resources. Applicable Mitigation Measures from the SEIR
The CAP Update would not result in more significant impacts related to biological resources. Mitigation
Measures BIO-2 and BIO-6 from the 2024 SEIR would apply to the CAP Update and ensure CAP Update
impacts related to biological resources are less than significant.
BIO-2 Pre-Construction Bird Surveys, Avoidance, and Notification
If construction activities are initiated during the bird nesting season (February 1 – August 31) involving
removal of vegetation or other nesting bird habitat, including abandoned structures and other man-
made features, a pre-construction nesting bird survey shall be conducted no more than three days
prior to initiation of ground disturbance and vegetation removal activities. The nesting bird pre-
construction survey shall be conducted on foot and shall include a 300-foot survey buffer around the
construction site. The survey shall be conducted by a biologist familiar with the identification of avian
species known to occur in southern California coastal communities (i.e., qualified biologist). If active
nests are found, an avoidance buffer shall be determined by a qualified biologist in coordination with
the city. The avoidance buffer width will depend upon the species, the proposed work activity, and
existing disturbances associated with land uses outside of the site, which shall be demarcated by the
biologist with bright orange construction fencing, flagging, construction lathe, or other means to
demarcate the boundary. All construction personnel shall be notified as to the existence of the buffer
zone and to avoid entering the buffer zone during the nesting season. No ground disturbing activities
shall occur within the buffer until the biologist has confirmed that breeding/nesting is completed, and
the young have fledged the nest. Encroachment into the buffer shall occur only at the discretion of
the qualified biologist on the basis that the encroachment will not be detrimental to an active nest. A
report summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and shall
be submitted to the city prior to the commencement of construction activities.
Oct. 2, 2024 Item #1 57 of 157
BIO-6 Protected Tree and Tree Canopy Survey
Prior to the issuance of a grading permit, a tree survey shall be conducted by a certified arborist prior
to project construction to tag and assess all trees subject to the city’s Trees and Shrubs Ordinance
(Municipal Code Title 11.12) and/or CFMP. A city arborist will inspect the property and recommend
approving or denying the application in a written report submitted to the City Manager. The city shall
post a letter of notification and a non-removable marking upon the subject tree a minimum of 30 days
prior to its removal. The letter will be posted in a prominent location, visible from a public street and
will include, the location of the tree, the reason for the trees removal, the date of the scheduled
removal, the species of tree to be replanted, the size of the tree to be replanted, the date by which an
appeal must be made to the parks and recreation commission, and a description of the appeal process.
The following measures shall be implemented in addition to those required under the city’s permits
required for tree removal and maintenance ordinance Guidelines (Municipal Code Title 11.12.090) to
avoid and/or compensate for potential indirect impacts to preserved sensitive natural communities
and protected trees within Carlsbad before, during, and following construction activities.
PRE-CONSTRUCTION
• Fencing. Protective fencing at least three feet high with signs and flagging shall be erected
around all preserved sensitive natural communities where adjacent to proposed vegetation
clearing and grubbing, grading, or other construction activities. The protective fence shall be
installed at a minimum of five feet beyond the tree canopy dripline. The intent of protection
fencing is to prevent inadvertent limb/vegetation damage, root damage and/or compaction
by construction equipment. The protective fencing shall be depicted on all construction plans
and maps provided to contractors and labeled clearly to prohibit entry, and the placement of
the fence in the field shall be approved by a qualified biologist prior to initiation of
construction activities. The contractor shall maintain the fence to keep it upright, taut and
aligned at all times. Fencing shall be removed only after all construction activities are
completed.
• Pre-Construction Meeting. A pre-construction meeting shall be held between all site
contractors and a registered consulting arborist and/or a qualified biologist. All site
contractors and their employees shall provide written acknowledgement of their receiving
sensitive natural community protection training. This training shall include, but shall not be
limited to, the following information: (1) the location and marking of protected sensitive
natural communities; (2) the necessity of preventing damage to these sensitive natural
communities; and (3) a discussion of work practices that shall accomplish such.
DURING CONSTRUCTION
• Fence Monitoring. The protective fence shall be monitored regularly (at least weekly) during
construction activities to ensure that the fencing remains intact and functional, and that no
encroachment has occurred into the protected natural community; any repairs to the fence
or encroachment correction shall be conducted immediately.
• Equipment Operation and Storage. Contractors shall avoid using heavy equipment around
the sensitive natural communities. Operating heavy machinery around the root zones of
trees would increase soil compaction, which decreases soil aeration and, subsequently,
reduces water penetration into the soil. All heavy equipment and vehicles shall, at minimum,
stay out of the fenced protected zones, unless where specifically approved in writing and
under the supervision of a registered consulting arborist and/or a qualified biologist.
Oct. 2, 2024 Item #1 58 of 157
• Materials Storage and Disposal. Contractors shall not store or discard any construction
materials within the fenced protected zones and shall remove all foreign debris within these
areas. The contractors shall leave the duff, mulch, chips, and leaves around the retained
trees for water retention and nutrient supply. Contractors shall avoid draining or leakage of
equipment fluids near retained trees. Fluids such as gasoline, diesel, oils, hydraulics, brake
and transmission fluids, paint, paint thinners, and glycol (anti-freeze) shall be disposed of
properly. The contractors shall ensure that equipment be parked at least 50 feet, and that
equipment/vehicle refueling occur at least 100 feet, from fenced protected zones to avoid
the possibility of leakage of equipment fluids into the soil.
• Grade Changes. Contractors shall ensure that grade changes, including adding fill, shall not
be permitted within the fenced protected zone without special written authorization and
under supervision by a registered consulting arborist and/or a qualified biologist. Lowering
the grade within the fenced protected zones could necessitate cutting main support and
feeder roots, thus jeopardizing the health and structural integrity of the tree(s). Adding soil,
even temporarily, on top of the existing grade could compact the soil further, and decrease
both water and air availability to the tree roots. Contractors shall ensure that grade changes
made outside of the fenced protected zone shall not create conditions that allow water to
pond.
• Trenching. Except where specifically approved in writing beforehand, all trenching shall be
outside of the fenced protected zone. Roots primarily extend in a horizontal direction
forming a support base to the tree similar to the base of a wineglass. Where trenching is
necessary in areas that contain roots from retained trees, contractors shall use trenching
techniques that include the use of either a root pruner (Dosko root pruner or equivalent) or
an Air-Spade to limit root impacts. An International Society of Arboriculture (ISA) certified
arborist or American Society of Consulting Arborists (ASCA) registered consulting arborist
shall ensure that all pruning cuts shall be clean and sharp, to minimize ripping, tearing, and
fracturing of the root system. Root damage caused by backhoes, earthmovers, dozers, or
graders is severe and may ultimately result in tree mortality. Use of both root pruning and
Air-Spade equipment shall be accompanied only by hand tools to remove soil from trench
locations. The trench shall be made no deeper than necessary.
• Erosion Control. Appropriate erosion control best management practices (BMPs) shall be
implemented to protect preserved sensitive natural communities during and following
project construction. Erosion control materials shall be certified as weed free.
• Inspection. An ISA certified arborist or ASCA registered consulting arborist shall inspect the
preserved trees adjacent to grading and construction activity on a monthly basis for the
duration of the grading and construction activities. A report summarizing site conditions,
observations, tree health, and recommendations for minimizing tree damage shall be
submitted by the registered consulting arborist following each inspection.
POST-CONSTRUCTION
• Mulch. The contractors shall ensure that the natural duff layer under all trees adjacent to
construction activities shall be maintained. This would stabilize soil temperatures in root zones,
conserve soil moisture, and reduce erosion. The contractors shall ensure that the mulch be
kept clear of the trunk base to avoid creating conditions favorable to the establishment and
growth of decay causing fungal pathogens. Should it be necessary to add organic mulch
beneath retained oak trees, packaged or commercial oak leaf mulch shall not be used as it may
Oct. 2, 2024 Item #1 59 of 157
contain root fungus. Also, the use of redwood chips shall be avoided as certain inhibitive
chemicals may be present in the wood. Other wood chips and crushed walnut shells can be
used, but the best mulch that provides a source of nutrients for the tree is its own leaf litter.
Any added organic mulch added by the contractors shall be applied to a maximum depth of 4
inches where possible.
• Watering Adjacent Plant Material. All installed landscaping plants near the preserved
sensitive natural communities shall require moderate to low levels of water. The surrounding
plants shall be watered infrequently with deep soaks and allowed to dry out in-between,
rather than frequent light irrigation. The soil shall not be allowed to become saturated or stay
continually wet, nor should drainage allow ponding of water. Irrigation spray shall not hit the
trunk of any tree. The contractors shall maintain a 30-inch dry-zone around all tree trunks. An
above ground micro-spray irrigation system shall be used in lieu of typical underground pop-
up sprays.
• Monitoring. An ISA certified arborist or ASCA registered consulting arborist shall inspect the
trees preserved on the site adjacent to construction activities for a period of two years following
the completion of construction. Monitoring visits shall be completed quarterly, totaling eight
visits. Following each monitoring visit, a report summarizing site conditions, observations, tree
health, and recommendations for promoting tree health shall be submitted to the city.
Additionally, any tree mortality shall be noted and any tree dying during the two-year
monitoring period shall be replaced at a minimum 3:1 ratio on-site in coordination with the city.
Oct. 2, 2024 Item #1 60 of 157
Cultural Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Cause a substantial adverse
change in the significance of a
historical resource pursuant to
§15064.5?
Significant and
Unavoidable None No No No Yes Yes
b. Cause a substantial adverse
change in the significance of an
archaeological resource pursuant
to §15064.5?
Less than
Significant None No No No Yes Yes
c. Disturb any human remains,
including those interred outside
of formal cemeteries?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 61 of 157
Previous CEQA Analysis Cultural Resources Findings
The 2024 SEIR identified a significant and unavoidable impact related to a substantial adverse change in
the significance of a historical resource pursuant to §15064.5 and identified no feasible mitigation
measures (CUL-1). The 2024 SEIR identified a less than significant impact related to a substantial adverse
change in the significance of an archaeological resource pursuant to §15064.5 (CUL-2). The 2024 SEIR
also identified a less than significant impact for disturbing any human remains, including those interred
outside of formal cemeteries (CUL-3) (Section 4.4, Cultural and Tribal Cultural Resources).
Addendum Analysis
Implementation of the CAP Update would result in physical changes to the environment that could
occur in proximity to or involve encountering historical resources. For example, some improvements
that result from the CAP Update, such as Measures T-1, T-4, T-5, T-8, T-9, CS-1, E-3.3, W-1, and W-2,
would require limited ground disturbance. Energy efficiency improvements and building retrofits
(Measure E-6) would involve minor changes to the exterior (e.g., rooftop solar panels) or interior (e.g.,
water heating and space heating and cooling systems) of existing buildings, and would not otherwise
involve features with substantial height, bulk, or massing that would cause a substantial adverse change
to a historic resource. Adherence to the relevant General Plan policies, the Historic Preservation
Ordinance, and the relevant elements of the Carlsbad Cultural Resource Guidelines would protect
historical resources from substantial adverse changes during CAP Update implementation.
Because ground disturbance associated with the implementation of CAP Update Measures T-1, T-4, T-
5, T-8, T-9, CS-1, E-3.3, W-1, and W-2 would be limited to shallow depths, comprised of artificial fill or
previously disturbed soils, archaeological resources are unlikely to be encountered. In addition,
construction activities associated with CAP Update implementation would occur in already disturbed
developed areas such as roadways and parking lots. Zero emission vehicle charging stations (Measure
T-8) would be installed in new and existing developments, and roadway improvements such as
roundabouts, traffic circles, walkways, and bicycle infrastructure would occur along existing developed
roadways. In addition, tree planting associated with Measure CS-1 would likely occur within city parks
and public rights-of-way. Furthermore, the Carlsbad Cultural Resource Guidelines addresses treatment
of cultural resources to avoid substantial adverse effects should they be encountered during ground
disturbance activities associated with the CAP Update. Therefore, with adherence to the Carlsbad
Cultural Resource Guidelines, implementation of the CAP Update would not cause a substantial
adverse change in the significance of an archaeological resource pursuant to §15064.5.
The Carlsbad Cultural Resource Guidelines Standard Treatment 11: Post-Review Discoveries section
addresses treatment of human remains should they be disturbed as a result of ground disturbing
activities. Moreover, human burials, in addition to being potential archaeological resources, have
specific provisions for treatment in Public Resources Code (PRC) Section 5097. The California Health
and Safety Code (Section 7050.5, 7051, and 7054) has specific provisions for the protection of human
burial remains. Existing regulations address the illegality of interfering with human burial remains, and
protect them from disturbance, vandalism, or destruction. They also include established procedures
to be implemented if Native American skeletal remains are discovered. PRC Section 5097.98 also
addresses the disposition of Native American burials, protects such remains, and provides for the
establishment of the NAHC to resolve any related disputes. All development projects are also subject
to State of California Health and Safety Code Section 7050.5 which states that, if human remains are
unearthed, no further disturbance can occur until the county coroner has made the necessary findings
as to the origin and disposition of the remains pursuant to the PRC Section 5097.98.
Oct. 2, 2024 Item #1 62 of 157
If the remains are determined to be of Native American descent, the coroner has 24 hours to notify
the Native American Heritage Commission which will determine and notify a most likely descendant
(MLD). The MLD shall complete the inspection of the site and make recommendations to the
landowner within 48 hours of being granted access. With adherence to these existing regulations as
well as the Carlsbad Cultural Resource Guidelines, implementation of the CAP Update would not
disturb any human remains, including those interred outside of formal cemeteries.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to cultural resources. The 2024 SEIR identified a
significant and unavoidable impact for cultural resources (CUL-1) and did not identify feasible
mitigation measures. The CAP Update would not result in any new or substantially more severe
significant impacts related to cultural resources. Applicable Mitigation Measures from the SEIR
There are no feasible mitigation measures from the 2024 SEIR to reduce impacts related to cultural
resources.
Oct. 2, 2024 Item #1 63 of 157
Energy
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Result in potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction and operation?
No Impact None No No No Yes Yes
b. Conflict with or obstruct a State or
local plan for renewable energy or
energy efficiency?
No Impact None No No No Yes Yes
Oct. 2, 2024 Item #1 64 of 157
Previous CEQA Analysis Energy Findings
The 2024 SEIR identified no impact for the wasteful, inefficient, or unnecessary consumption of energy
resources, during project construction or operation or for conflicts with or obstruction of a State or
local plan for renewable energy or energy efficiency (Section 4.16.2, Energy).
Addendum Analysis
Construction activities associated with implementation of the CAP Update measures and actions
would result in short-term consumption of energy resulting from the use of construction equipment.
The types of construction activities associated with the CAP Update would vary depending on the type
of CAP Update measure. Examples of activities that would result from implementation of CAP Update
measures include construction of new public zero emission vehicle and bicycle charging infrastructure,
building efficiency retrofits, roundabouts or traffic circles, bicycle infrastructure, new solar carports,
and water and wastewater system improvements (e.g., Measures T-1, T-2, T-3, T-4, T-5, T-8, T-9, E-3.3,
W-1, and W-2). These activities would consume energy resources such as electricity, fuels, and non-
renewable resources during construction. In addition, construction materials require energy to be
produced, and would likely be used in projects that involve new construction or replacement of older
materials. The California Green Building Standards Code (CALGreen) includes specific requirements
related to recycling, construction materials, and energy efficiency standards, which would apply to
construction projects envisioned by the CAP Update and help to minimize waste and energy
consumption. Although implementation of the CAP Update would result in short-term construction
activities that would consume energy resources, standard best management practices would discourage
unnecessary idling and the operation of poorly maintained equipment during construction. In addition,
the CAP Update includes measures that would reduce nonrenewable energy consumption during
construction activities. For example, Measure OR-2 would increase the use of renewable and
alternative fuel construction equipment, while Measure T-9 would establish city fleet regulations for
idling, thus reducing construction vehicle idling time and further reducing construction related energy
consumption.
Implementation of the CAP Update would improve operational energy efficiency and reduce the use of
fossil fuels, for example through measures which reduce VMT (Measure T-2) and encourage zero
emission vehicle use (Measure T-8), as well as measures which facilitate the increased generation and
utilization of renewable energy Measures E-1 through E-6). The measures and actions in the CAP Update
reduce GHG emissions, primarily by improving energy efficiency and decreasing consumption of fossil
fuels and nonrenewable energy consumption. Thus, implementation of the CAP Update would not result
in wasteful, inefficient, or unnecessary consumption of energy, consistent with the SEIR findings.
Where applicable, measures and actions associated with the CAP Update would be required to comply
with CALGreen, the latest California Building Code (CBC) requirements, including CBC Energy Efficiency
Standards, as well as all federal, State, and local rules and regulations pertaining to energy
consumption and conservation. Through implementation of city policies as delineated in the city’s
General Plan, and concurrent implementation of the CAP Update, measures and actions would support
the San Diego Regional Energy Strategy renewable energy goals and would not conflict with any
applicable plan, policy, or regulation adopted regarding renewable energy or energy efficiency.
Oct. 2, 2024 Item #1 65 of 157
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to energy. The 2024 SEIR did not identify significant
energy impacts and did not identify mitigation measures. The CAP Update would not result in any new
or substantially more severe significant impacts related to energy. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to energy.
Oct. 2, 2024 Item #1 66 of 157
Geology and Soils
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within
the Scope
of the
SEIR?
Would implementation of the CAP Update:
a. Directly or indirectly cause
potential substantial adverse
effects, including the risk of loss,
injury, or death involving:
i. Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial
evidence of a known fault? Refer
to Division of Mines and Geology
Special Publication 42.
Less than
Significant None No No No Yes Yes
ii. Strong seismic ground shaking? Less than
Significant None No No No Yes Yes
iii. Seismic-related ground failure,
including liquefaction? Less than
Significant None No No No Yes Yes
iv. Landslides? Less than Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 67 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
b. Result in substantial soil erosion or the loss of topsoil? Less than Significant None No No No Yes Yes
c. Be located on a geologic unit or soil that is unstable, or that would become
unstable as a result of the project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction, or collapse?
Less than Significant None No No No Yes Yes
d. Be located on expansive soil, as defined in Table 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Less than Significant None No No No Yes Yes
e. Have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not
available for the disposal of wastewater?
Less than Significant None No No No Yes Yes
f. Directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 68 of 157
Previous CEQA Analysis Geology and Soils Findings
The 2024 SEIR identified less than significant impacts for the risk of loss, injury, or death involving
rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a
known fault (GEO-1); and for the risk of loss, injury, or death involving strong seismic ground shaking,
seismic-related ground failure, including liquefaction or landslides (GEO-2). The 2024 SEIR also
identified less than significant impacts for substantial soil erosion or the loss of topsoil (GEO-3) and for
on or off-site landslide, lateral spreading, subsidence, liquefaction or collapse, and location on
expansive soils creating substantial direct or indirect risks to life or property (GEO-4). The 2024 SEIR
identified less than significant impacts for soils incapable of adequately supporting the use of septic
tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater (GEO-5) and for the project to directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature (GEO-6) (Section 4.5, Geology and Soils).
Addendum Analysis
Measures and actions associated with the CAP Update include improvements to energy infrastructure
(Measures E-1 through E-6), development of roundabouts (Measure T-1), bicycle infrastructure
(Measure T-4), pedestrian infrastructure (Measure T-5), and improvements to water and wastewater
infrastructure (Measures W-1, W-2). The measures identified in the CAP Update do not propose new
housing nor do they propose changes to policies or regulations related to land use or residential zoning.
Therefore, the CAP Update would not result in the risk of loss, injury, or death involving rupture of a
known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area or based on other substantial evidence of a known fault or
result in the risk of loss, injury, or death involving strong seismic ground shaking, seismic-related ground
failure, including liquefaction or landslides. The CAP Update would not result in substantial soil erosion
or the loss of topsoil or result in on or off-site landslide, lateral spreading, subsidence, liquefaction or
collapse, and location on expansive soils creating substantial direct or indirect risks to life or property.
The measures and actions in the CAP Update would not require use of septic tanks or alternative
wastewater disposal systems where sewers are not available for the disposal of wastewater.
Implementation of the CAP Update would include measures and actions (Measures T-1, T-4, T-5, T-8, T-
9, CS-1, E-3.3, W-1, and W-2) that involve ground disturbing activities which could encounter
paleontological resources in areas with moderate to high sensitivity. While encountering paleontological
resources is possible during CAP Update implementation, it is unlikely because of the shallow depth of
below ground disturbance associated with activities such as trenching to install zero emission vehicle
and bicycle charging infrastructure and making improvements to public roadway rights-of-way to
support walking and biking. For measures and actions requiring ground disturbance in areas underlain
by sensitive geologic units, the Carlsbad Cultural Resource Guidelines require a review of primary
literature and online databases, a paleontological assessment of the project area (plus a one-mile radius)
by the San Diego Museum of Natural History, and a field survey to determine if paleontological resources
or potentially fossiliferous sediments are present (if the sensitive sediments are exposed at the surface).
The results of these analyses are used to create a Paleontological Assessment Report which will provide
recommendations to mitigate impacts to paleontological resources, if necessary. The Carlsbad Cultural
Resource Guidelines set forth mitigation measures.
Additionally, General Plan policies 7-P.7 through 7-P.11 of the Arts, History, Culture, and Education
Element would reduce impacts to paleontological resources by implementing the Carlsbad Cultural
Resource Guidelines; requiring monitoring of ground-disturbing activities in areas known to contain
Oct. 2, 2024 Item #1 69 of 157
paleontological resources; and ensuring proper treatment and consultation of paleontological resources
discovered during ground-disturbing activities. With compliance with these guidelines and General Plan
policies, implementation of the CAP Update would not directly or indirectly destroy a unique
paleontological resource or site or unique geologic feature.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to geology and soils. The 2024 SEIR did not identify
significant geology and soils impacts and did not identify mitigation measures. The CAP Update would
not result in any new or substantially more severe significant impacts related to geology and soils. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to geology
and soils.
Oct. 2, 2024 Item #1 70 of 157
Greenhouse Gas Emissions
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
Significant
and
Unavoidable
GHG-1 No No No Yes Yes
b. Conflict with an applicable plan,
policy, or regulation adopted for
the purpose of reducing the
emissions of greenhouse gases?
Significant
and
Unavoidable
GHG-1 No No No Yes Yes
Oct. 2, 2024 Item #1 71 of 157
Previous CEQA Analysis Greenhouse Gas Emissions Findings
The 2024 SEIR identified a significant and unavoidable impact for generating greenhouse gas
emissions, either directly or indirectly, that may have a significant impact on the environment and for
conflicting with an applicable plan, policy, or regulation adopted for the purpose of reducing the
emissions of greenhouse gases (GHG-1). It identifies Mitigation Measure GHG-1, which requires the
preparation of this CAP Update to reduce the GHG emissions impacts identified in the 2024 SEIR
(Section 4.6, Greenhouse Gas Emissions).
Addendum Analysis
The CAP Update establishes measures and actions that would reduce GHG emissions in Carlsbad to
levels that achieve its GHG reduction targets, which are aligned with the State’s GHG reduction goals.
The city’s 2035 target requires GHG emissions to be reduced 50 percent below 2016 levels (aligned
with and extrapolated from SB 32) and reduced to 85 percent below 2016 levels by 2045 (aligned with
AB 1279). The CAP Update measures and actions would meet the city’s GHG reduction targets.
In addition, implementation of the CAP Update would result in physical changes to the environment
that would involve short-term physical changes that could result in GHG emissions. Several of the
measures and actions identified in the CAP Update promote construction of new facilities or retrofitting
of existing facilities that would generate construction-related GHG emissions. Some examples of
activities that would generate construction-related GHG emissions include retrofitting of existing
buildings and developments to transition to renewable energy generation (Measures E-1, E-6, W-1, and
W-2), constructing roundabouts or traffic circles (Measure T-1), installation of solar carports (Measure
E-3.3), installation of zero emission vehicle charging stations (Measure T-8), improvements to
pedestrian and bicycling infrastructure (Measures T-5 and T-4), and implementation of activities related
to urban tree planting (Measure CS-1).
Implementation of the CAP Update would reduce overall GHG emissions generated within the city, for
example by encouraging the use of alternative fuels in vehicles and equipment (Measures T-8, OR-1, and
OR-2), reducing VMT (Measures T-5, T-7, and T-10), improving energy efficiency (Measures E-1 through
E-6), reducing waste generation (Measure WD-1), and increasing carbon sequestration (Measure CS-1).
In addition, measures that support energy efficiency and renewable energy generation would reduce
GHG emissions at power plants generating electricity that serve the city. Thus, any temporary GHG
emissions would be offset by the overall net benefit of GHG emissions reduction after implementation
of the CAP Update. Therefore, implementation of the CAP Update would not generate GHG emissions,
either directly or indirectly, that may have a significant impact on the environment, nor would
implementation of the CAP Update conflict with an applicable plan, policy, or regulation adopted for the
purpose of reducing the emissions of GHGs.
Conclusion
There are no changes in circumstances or new information of substantial importance that would require
major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in the severity
of previously identified effects related to GHG emissions. Implementation of Mitigation Measure GHG-1,
which requires preparation of the CAP Update evaluated in this Addendum No. 1, would be satisfied by
preparation of the CAP Update, and therefore is not applicable to actions implementing the CAP Update.
The CAP Update would not result in any new or substantially more severe significant impacts related to
GHG emissions.
Oct. 2, 2024 Item #1 72 of 157
Applicable Mitigation Measures from the SEIR
The CAP Update satisfies the requirements of 2024 SEIR mitigation measure GHG-1; no other
mitigation measures related to GHG emissions impacts are identified in the 2024 SEIR.
Oct. 2, 2024 Item #1 73 of 157
Hazards and Hazardous Materials
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Create a significant hazard to the
public or the environment through
the routine transport, use, or
disposal of hazardous materials?
Less than Significant None No No No Yes Yes
b. Create a significant hazard to the
public or the environment through
reasonably foreseeable upset and
accident conditions involving the
release of hazardous materials
into the environment?
Less than Significant None No No No Yes Yes
c. Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within one-quarter mile
of an existing or proposed school?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 74 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance Conclusion
SEIR
Mitigation Measures
Do the Proposed
Changes Involve
a New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Are There New
Circumstances
Involving a New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Is There New
Information of Substantial
Importance
Requiring
New Analysis
or Verification?
Are Only Minor
Technical Changes
or Additions Necessary or Did
None of the
Conditions
Described in
§15162 Occur? (§15164(a))
Project is
within the
Scope of the SEIR?
d. Be located on a site which is
included on a list of hazardous material sites compiled pursuant
to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less than
Significant None No No No Yes Yes
e. For a project located within an airport land use plan area, or where such a plan has not been adopted, within two miles of a
public airport or public use airport, would the project result in a safety
hazard or excessive noise for people residing or working in the
project area?
Less than
Significant None No No No Yes Yes
f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 75 of 157
Previous CEQA Analysis Hazards and Hazardous Materials Findings
The 2024 SEIR identified less than significant impacts for the routine transport, use, or disposal of
hazardous materials and reasonably foreseeable upset and accident conditions involving the release
of hazardous materials (HAZ-1); emitting or handling hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school (HAZ-2); being located
on a site which is included on a list of hazardous materials sites compiled pursuant to Government
Code Section 65962.5 and creating a significant hazard to the public or the environment (HAZ-3); being
located within an airport land use plan or within two miles of a public airport or public use airport and
resulting in a safety hazard or excessive noise for people residing or working in the project area (HAZ-
4); and for impairing implementation of or physically interfering with an adopted emergency response
plan or emergency evacuation plan (HAZ-5) (Section 4.7, Hazards and Hazardous Materials).
Addendum Analysis
The implementation of the CAP Update measures and actions would result in short-term and long-
term changes related to hazards and hazardous materials as described below.
Construction activities and routine maintenance associated with implementation of the CAP Update
would result in short-term, temporary changes to hazards and hazardous materials conditions in the
city. Although the types of construction activities associated with the CAP Update would vary
depending on the type of CAP Update measure, they could result in an increase in the overall routine,
transport, use and disposal of hazardous materials in the city for construction activities. For example,
Measures T-1, T-4, T-5, T-8, and T-9 would involve removing existing pavement; repaving roadway
surfaces; painting or restriping pavement; modifying curbs; laying concrete, and installing traffic
signals, lighting, landscaping, street furniture, and other amenities. Construction activities would be
short-term and temporary and would be required to comply with relevant federal, State, and local
regulations that require strict adherence to guidelines regarding the safe use, transportation, and
disposal of hazardous materials as well as ensuring the reduction of the potential for humans or the
environment to be affected by an accidental release of hazardous materials. Enforcement of these
regulatory standards would ensure that the measures and actions facilitated by implementation of the
CAP Update would not create a significant hazard through reasonably foreseeable upset and/or
accident conditions involving the release of hazardous materials into the environment. Compliance
with applicable regulations would ensure that any hazardous materials used during the
implementation of the CAP Update would not result in hazardous emissions within one-quarter mile
of an existing or proposed school.
Some improvements as a result of the CAP Update, such as Measures E-3.3, W-1, and W-2, would
require limited ground disturbance which could result in the release of contaminants into the
environment, if they are present in the underlying soils and/or groundwater. In the event that CAP
Update implementation results in ground disturbance, any residual contamination that is encountered
would be remediated to allowable regulatory levels in accordance with applicable county and State
regulations before any ground-disturbing activities are permitted to occur. Therefore, implementation
of the CAP Update would not result in a significant hazard to the public or the environment due to
being located on a hazardous materials site.
The McClellan–Palomar Airport is located near the center of the city and has a Land Use Compatibility
Plan (ALUCP) developed and adopted by the San Diego County Airport Land Use Commission in 2010
and last amended in 2011 (San Diego County Regional Airport Authority 2011). The CAP Update
measures and actions would not result in new or relocated residential land uses, other types of noise-
Oct. 2, 2024 Item #1 76 of 157
sensitive receptors, or new places of permanent employment where residents or workers could be
exposed to a safety hazard or excessive noise. Therefore, implementation of the CAP Update would
not expose residents or workers to a safety hazard or excessive noise levels.
Long-term changes resulting from implementation of CAP Update measures and actions would include
improvements at or near grade level of existing roadways, new and upgraded bikeways and sidewalks
along existing developed roadways and rights-of-way in the city, the installation of roundabouts or
traffic circles to control traffic within the intersections of existing developed roadways, and the
installation of zero emission charging infrastructure (through implementation of Measures T-1, T-4, T-
5, T-8, and T-9). However, these improvements would not adversely affect the capacity of roadways
during an emergency or evacuation. CAP Update Measure T-1, which encourages the installation of
roundabouts, would reduce congestion, thus increasing traffic flow and the ability to evacuate during
an emergency. Furthermore, the CAP Update measures and actions would comply with the San Diego
County Emergency Operations Plan (EOP) and the California Fire Code. Therefore, implementation of
the CAP Update would not impair or interfere with adopted emergency response or evacuation plans.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to hazards and hazardous materials. The 2024 SEIR
did not identify significant hazards and hazardous material impacts and did not identify mitigation
measures. The CAP Update would not result in any new or substantially more severe significant
impacts related to hazards and hazardous material. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to hazards
and hazardous materials.
Oct. 2, 2024 Item #1 77 of 157
Hydrology and Water Quality
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface or
ground water quality?
Less than
Significant None No No No Yes Yes
b. Substantially decrease
groundwater supplies or interfere
substantially with groundwater
recharge, such that the project
may impede sustainable
groundwater management of the
basin?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 78 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR Significance
Conclusion
SEIR Mitigation
Measures
Do the Proposed
Changes Involve a New or
Substantial
Increase in the
Severity of
Previously Identified
Impacts?
Are There New
Circumstances
Involving a New or
Substantial
Increase in the
Severity of
Previously Identified
Impacts?
Is There New Information
of Substantial
Importance
Requiring
New Analysis or
Verification?
Are Only Minor
Technical
Changes or Additions
Necessary or Did
None of the
Conditions
Described in §15162 Occur?
(§15164(a))
Project is
within the Scope of
the SEIR?
c. Substantially alter the existing
drainage pattern of the site or area,
including through the alteration of
the course of a stream or river or
through the addition of impervious
surfaces in a manner which would:
i. result in substantial erosion or
siltation, on- or off-site;
ii. substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or offsite;
iii. create or contribute runoff water which would exceed the capacity
of existing or planned
stormwater drainage systems or
provide substantial sources of
polluted runoff; or
iv. impede or redirect flood flows?
Less than
Significant None No No No Yes Yes
d. In flood hazard, tsunami, or seiche
zones, risk release of pollutants due
to project inundation?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 79 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance Conclusion
SEIR
Mitigation Measures
Do the Proposed
Changes Involve
a New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Are There
New
Circumstances
Involving a
New or Substantial
Increase in
the Severity
of Previously
Identified Impacts?
Is There New Information of
Substantial
Importance
Requiring New
Analysis or Verification?
Are Only Minor
Technical
Changes or
Additions Necessary or Did
None of the
Conditions
Described in
§15162 Occur? (§15164(a))
Project is
within the
Scope of the SEIR?
e. Conflict with or obstruct
implementation of a water quality
control plan or sustainable
groundwater management plan?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 80 of 157
Previous CEQA Analysis Hydrology and Water Quality Findings
The 2024 SEIR identified less than significant impacts related to the violation of water quality
standards, waste discharge requirements (WDR’s), or otherwise degradation of surface or ground
water quality (HYD-1); decreasing groundwater supplies or interfering with groundwater recharge
(HYD-2); altering the existing drainage patterns through the alteration of the course of a stream or
river or through the addition of impervious surfaces resulting in substantial erosion or siltation on- or
off-site, increasing the rate or amount of surface runoff in a manner which would result in flooding
on- or off-site, or creating or contributing runoff water which would exceed the capacity of existing or
planned stormwater drainage systems or provide substantial additional sources of polluted runoff
(HYD-3); impede or redirect flood flows or in flood hazard, tsunami, or seiche zones risk release of
pollutants due to project inundation (HYD-4); conflicts with or obstruction of implementation of a
water quality control plan or sustainable groundwater management plan (HYD-5) (Section 4.8,
Hydrology and Water Quality).
Addendum Analysis
The implementation of the CAP Update measures and actions would result in short-term and long-
term changes related to hydrology and water quality as described below.
The CAP Update measures involving construction activity would require minor grading, excavation,
and other ground disturbance associated with removing existing pavement; repaving roadway
surfaces; painting or restriping pavement; modifying curbs; laying concrete, and installing traffic
signals, lighting, landscaping, street furniture, and other amenities (through implementation of
Measures T-1, T-4, T-5, T-8, and T-9). Measures E-3.3, W-1, W-2, and CS-1 would also involve ground-
disturbing activities, which could, depending on their location, potentially cause soil erosion which in
turn can contaminate nearby surface water. However, implementation of the measures and actions in
the CAP Update would be required to comply with State and local water quality regulations designed
to control erosion and protect water quality during construction. This includes compliance with the
requirements of the State Water Resources Control Board (SWRCB) Construction General Permit,
which requires preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP)
for projects that disturb one acre or more of land. Erosion and sediment controls identified in the
SWPPP would substantially reduce the amount of soil disturbance, erosion, and sediment transport
into receiving waters, and pollutants in site runoff during construction. The CMC also sets forth
requirements and BMPs pertaining to the mitigation of erosion, sediment control and runoff as outlined
in CMC Chapter 15.12 and Chapter 15.16. Through compliance with all applicable regulations and
permits, implementation of the CAP Update would not violate any water quality standards or WDRs
or otherwise substantially degrade water quality; substantially alter the existing drainage pattern of
the site or area, including through the alteration of the course of a stream or river or through the
addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on-
or off-site, increase the rate or amount of surface runoff in a manner which would result in flooding
on- or off-site, or create or contribute runoff water which would exceed the capacity of existing or
planned stormwater drainage systems or provide substantial additional sources of polluted runoff.
The CAP Update measures and actions involving ground disturbing activities (Measures T-1, T-4, T-5,
T-8, T-9, E-3.3, W-1, W-2, CS-1) could require the use of water for dust abatement as needed via a
water truck. However, the ground disturbing activities would be temporary and intermittent and
would not involve the substantial use of groundwater or otherwise affect recharge such that there
would be a net deficit in aquifer volume or a lowering of the local groundwater table level.
Oct. 2, 2024 Item #1 81 of 157
Furthermore, implementation of the CAP Update would not involve development of residential land
uses or other types of land development or induce population growth in an area that would increase
water demand. In addition, the city requires new construction and redevelopment to use low impact
development (LID) techniques. These techniques would ensure that pervious surfaces are
incorporated into development that would be facilitated by the project. Therefore, implementation of
the CAP Update would not decrease groundwater supplies or interfere with groundwater recharge.
Long-term changes resulting from implementation of the CAP Update measures would include
improvements at or near grade level of existing roadways, as well as minor changes to traffic intersections
and walkways (through implementation of Measures T-1, T-4, T-5, T-8, and T-9), improvements to water
and wastewater systems (Measures W-1 and W-2), and the planting of trees (through implementation of
Measure CS-1). The CMC requires BMPs to control the volume, rate, and potential pollutant load of
stormwater runoff from new development and redevelopment projects as a requirement of the
Municipal Stormwater Permit. Furthermore, the city’s LID ordinance in Chapter 15.12.080 aims to
specifically reduce the amount of surface runoff and aid in groundwater recharge through techniques
such as infiltration, evapotranspiration, bioretention and/or rainfall harvest and additional uses in
accordance with the requirements set forth in the MS4 permit and the LID standards manual. Given
compliance with the above regulations and requirements, implementation of the CAP Update would not
alter the existing drainage patterns or contribute runoff water in a manner which would result in
substantial erosion, siltation, or flooding, nor would it exceed the capacity of existing or planned
stormwater drainage systems.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to hydrology and water quality. The 2024 SEIR did
not identify significant hydrology and water quality impacts and did not identify mitigation measures.
The CAP Update would not result in any new or substantially more severe significant impacts related
to hydrology and water quality. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to hydrology
and water quality.
Oct. 2, 2024 Item #1 82 of 157
Land Use and Planning
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Physically divide an established
community? No Impact None No No No Yes Yes
b. Cause a significant environmental
impact due to a conflict with any
land use plan, policy, or regulation
adopted for the purpose of
avoiding or mitigating an
environmental effect?
Less than Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 83 of 157
Previous CEQA Analysis Land Use and Planning Findings
The 2024 SEIR identified no impact for physically dividing an established community (LU-1) and a less
than significant impact for conflicts with any land use plan, policy, or regulation (LU-2) (Section 4.9,
Land Use and Planning).
Addendum Analysis
Implementation of the CAP Update would not result in physical improvements that could physically
divide a community. For example, measures resulting in construction of roundabouts or traffic circles
(T-1) and bikeways (T-4) would reduce vehicle congestion and encourage bicycle trips, which would
increase community connectivity and access. Implementation of Measure T-5 would also increase
community connectivity and access by adding 6.1 miles of sidewalk to existing infrastructure and
increasing the connectivity of sidewalk networks. As such, the CAP Update measures and actions are
intended to improve, rather than impair, community connectivity and access throughout the city.
Therefore, implementation of the CAP Update would not result in construction of physical barriers
that would physically divide an established community.
The CAP Update measures and actions would include improvements to the city’s existing pedestrian,
bicycle, and transit network within developed areas (Measures T-1, T-3, T-4, and T-5). Implementation
of the CAP Update would not change existing land uses and would comply with all applicable land use
plans, policies, and regulations, including SANDAG’s 2021 Regional Plan and the city’s 2015 General
Plan. Therefore, implementation of the CAP Update would not cause a significant environmental
impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of
avoiding or mitigating an environmental effect.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to land use and planning. The 2024 SEIR did not
identify significant land use and planning impacts and did not identify mitigation measures. The CAP
Update would not result in any new or substantially more severe significant impacts related to land use
and planning. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to land
use and planning.
Oct. 2, 2024 Item #1 84 of 157
Mineral Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Result in the loss of availability
of a known mineral resource
that would be of value to the
region and the residents of the
State?
No Impact None No No No Yes Yes
b. Result in the loss of availability
of a locally important mineral
resource recovery site
delineated on a local general
plan, specific plan, or other land
use plan?
No Impact None No No No Yes Yes
Oct. 2, 2024 Item #1 85 of 157
Previous CEQA Analysis Mineral Resources Findings
The 2024 SEIR identified no impacts to the loss of availability of a known mineral resource that would
be of value to the region and the residents of the State, or the loss of availability of a locally-important
mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan
(Section 4.16.3, Mineral Resources).
Addendum Analysis
Carlsbad does not have mineral resources of economic value or active mining sites (City of Carlsbad
2015), therefore the 2024 SEIR identified no impacts to the loss of availability of a known mineral
resource that would be of value to the region and the residents of the State, or the loss of availability
of a locally-important mineral resource recovery site delineated on a local general plan, specific plan,
or other land use plan. Similarly, implementation of the CAP Update would not result in the loss of
availability of a known mineral resource that would be of value to the region and the residents of the
State, or result in the loss of availability of a locally-important mineral resource recovery site
delineated on a local general plan, specific plan, or other land use plan.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to mineral resources. The 2024 SEIR did not identify
significant mineral resources impacts and did not identify mitigation measures. The CAP Update would
not result in any new or substantially more severe significant impacts related to mineral resources. Applicable Mitigation Measures from the SEIR There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to mineral
resources.
Oct. 2, 2024 Item #1 86 of 157
Noise
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve a
New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Are There New
Circumstances
Involving a
New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring New
Analysis or
Verification?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP
Update:
a. Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in
excess of standards established in the local general plan or noise
ordinance, or applicable standards of other agencies?
Significant and
Unavoidable
(construction)
Less than
Significant
(operation)
MM NOI-1 No No No Yes Yes
b. Generation of excessive groundborne vibration or
groundborne noise levels?
Less than
Significant
with
Mitigation
MM NOI-2 No No No Yes Yes
Oct. 2, 2024 Item #1 87 of 157
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 88 of 157
Previous CEQA Analysis Noise Findings
The 2024 SEIR identified that although mitigation measure NOI-1 would reduce construction noise
impacts for projects located within 500 feet of noise-sensitive land uses, it conservatively concluded
impacts to be significant and unavoidable related to construction activities generating a substantial
temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of
standards established in the local general plan or noise ordinance, or applicable standards of other
agencies (NOI-1). The 2024 SEIR identified a less than significant impact related to operational
activities generating a substantial temporary or permanent increase in ambient noise levels in the
vicinity of the project in excess of standards established in the local general plan or noise ordinance,
or applicable standards of other agencies (NOI-2). The 2024 SEIR identified a less than significant
impact related to the generation of excessive groundborne vibration or groundborne noise levels (NOI-
3) with implementation of mitigation measure NOI-2. The 2024 SEIR also identified a less than
significant impact related to excessive noise levels within the vicinity of a private airstrip or an airport
land use plan or (NOI-4) (Section 4.10, Noise).
Addendum Analysis
The implementation of the CAP Update measures and actions would result in short-term changes
related to noise as described below.
Construction activities associated with the implementation of the CAP Update, such as equipment use,
construction of new facilities or retrofitting of existing facilities, would result in construction-related
noise in the city. The types of construction activities associated with the CAP Update would vary
depending on the type of CAP Update measure. CAP Update measures that may result in the
generation of noise associated with construction activities include construction of new public zero
emission vehicle and bicycle charging infrastructure, building efficiency retrofits, roundabouts or
traffic circles, bicycle infrastructure, new solar carports, and water and wastewater system
improvements (e.g., Measures T-1, T-2, T-3, T-4, T-5, T-8, T-9, E-3.3, W-1, and W-2). Construction
activities associated with CAP Update measures and actions may involve using construction equipment
and vehicles to remove existing pavement; repave roadway surfaces; paint or restripe pavement;
modify curbs; lay concrete, and install traffic signals, lighting, landscaping, street furniture, and other
amenities. Construction equipment that could be used includes concrete saws for hardscape removal,
backhoes or mini excavators, skip loaders, smooth drum rollers, dump trucks, and striping and paving
machines, depending on the CAP Update measure. Construction activities associated with the CAP
Update would be short-term and would not involve equipment or activities, such as blasting or pile
driving that would result in the generation of a substantial temporary or permanent increase in
ambient noise levels or the generation of excessive groundborne vibration or groundborne noise levels.
Construction activities associated with the implementation of the CAP Update would not include two
subterranean levels or more (generally more than 20,000 cubic yards of excavated soil material), and
would be short term, thus avoiding a construction duration of 18 months. Construction activities
associated with the implementation of the CAP Update would not require use of large, heavy-duty
equipment types used in housing development projects or require pile driving, therefore, mitigation
measures NOI-1 andNOI-2 identified in the SEIR that were specific to impacts associated with housing
development permitted under implementation of the Housing Element Update would not apply to the
CAP Update.
Implementation of the CAP Update would be subject to existing city noise policies and regulations and
General Plan policies and programs, specifically those found in the Noise Element, and other local
agency polices and regulations pertaining to noise at any development site. Compliance with
Oct. 2, 2024 Item #1 89 of 157
Occupational Safety and Health Administration (OSHA) standards for worker safety would minimize
exposure of workers to excessive noise levels. Therefore, implementation of measures and actions
included in the CAP Update would not create a permanent increase in ambient noise levels or produce
a new permanent source of noise, and construction-related noise impacts would be reduced through
enforcement of applicable city or other local agency noise policies.
Long-term changes resulting from operation of the measures and actions in the CAP Update would not
permanently introduce any new stationary sources of noise (e.g., machinery, pumps, fans, compressors,
or other equipment) and would not generate new vehicle trips that would result in transportation-
related noise. The transportation-related measures such as Measures T-5, T-7, and T-10 would reduce
VMT in the city by improving street connectivity, provide resources and incentives for alternative
commutes, such as a carpool matching, and implement parking management strategies. Reducing
VMT would reduce transportation-related noise. Therefore, the CAP Update would not result in a
substantial temporary or permanent increase in ambient noise levels in excess of standards established
in the local general plan or noise ordinance, or applicable standards of other agencies or in the
generation of excessive groundborne vibration or groundborne noise levels.
The CAP Update does not propose any new sensitive receptors (e.g., residences, schools) that could
be adversely impacted from noise associated with aircraft flyovers. Temporary construction workers
would not be adversely affected by aircraft flyover as noise generated from construction equipment
would be the dominant noise exposure to them, which is generally dealt with by wearing ear plugs to
prevent hearing damage. Furthermore, long-term maintenance workers would not sleep on-site; thus,
they would not be exposed to potential sleep disturbance from aircraft flyovers. Thus, implementation
of the CAP Update would not expose people residing or working near an airport to excessive
airport/aircraft noise.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to noise. Implementation of mitigation measures
NOI-1 and NOI-2 from the 2024 SEIR are not applicable to the CAP Update. The CAP Update would not
result in any new or substantially more severe significant impacts related to noise. Applicable Mitigation Measures from the SEIR
The SEIR identified Mitigation Measures NOI-1 and NOI-2 for noise impacts. Neither of these
mitigation measures are applicable to the CAP Update.
Oct. 2, 2024 Item #1 90 of 157
Population and Housing
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a.Induce substantial unplanned
population growth in an area,
either directly (for example, by
proposing new homes and
businesses) or indirectly (for
example, through extension of
roads and other infrastructure)?
Less than
Significant None No No No Yes Yes
b.Displace substantial numbers of
existing housing or people,
necessitating the construction of
replacement housing
elsewhere?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 91 of 157
Previous CEQA Analysis Population and Housing Findings
The 2024 SEIR identified less than significant impacts for unplanned population growth (PH-1) and
substantial displacement of existing people or housing, necessitating the construction of replacement
housing elsewhere (PH-2) (Section 4.11, Population and Housing).
Addendum Analysis
Construction activities associated with the implementation of the CAP Update could require a
temporary increase in the number of construction workers traveling into the city to perform
construction work. These types of projects would be small, short-term, and temporary construction
projects, which would not require a large construction crew. Furthermore, construction workers
would likely be from Carlsbad or the greater San Diego region and permanent, substantial relocation
of workers would not be required. Therefore, implementation of the CAP Update would not result in
substantial population growth or employment growth in the city.
Implementation of the CAP Update would not displace people or housing because the measures and
actions in the CAP Update would not require the removal of existing housing and would not propose
changes to policies or regulations related to land use or residential zoning or otherwise increase
population growth in the city or surrounding areas. Therefore, implementation of the CAP Update
would not displace substantial numbers of existing people or housing, necessitating the construction of
replacement housing elsewhere.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to population and housing. The 2024 SEIR did not
identify significant population and housing impacts and did not identify mitigation measures. The CAP
Update would not result in any new or substantially more severe significant impacts related to
population and housing. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to
population and housing.
Oct. 2, 2024 Item #1 92 of 157
Public Services
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a.Result in substantial adverse
physical impacts associated with
the provision of new or physically
altered government facilities, the
construction of which could cause
significant environmental impacts,
in order to maintain acceptable
service ratios, response times, or
other performance objectives for
any of the public services:
• Fire?
• Police protection?
• Schools?
• Parks?
• Other public facilities?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 93 of 157
Previous CEQA Analysis Public Services Findings
The 2024 SEIR identified less than significant impacts associated with the provision of new or physically
altered government facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times, or other performance
objectives for any of the public services, including fire protection services (PS-1), police protection
services (PS-2), and schools (PS-3) (Section 4.12, Public Services and Recreation).
Addendum Analysis
The CAP Update would not generate new or increased demand for fire protection services or interfere
with or modify the ability of police and fire protection services to meet performance objectives or
response times outlined in the 2024 SEIR. The CAP Update does not include development of new
residences or the creation of substantial numbers of permanent jobs requiring increased fire or police
services. The CAP Update would not induce population growth in the community that would require
school services, new or expanded park facilities, other public facilities. The measures and actions from
the CAP Update would not generate increased demand for public services such that construction of
new or expanded facilities would be required to maintain adequate service ratios. Therefore,
implementation of the CAP Update would not result in substantial adverse physical impacts associated
with the provision of new or physically altered governmental facilities.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to public services. The 2024 SEIR did not identify
significant public services impacts and did not identify mitigation measures. The CAP Update would
not result in any new or substantially more severe significant impacts related to public services. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to public
services.
Oct. 2, 2024 Item #1 94 of 157
Recreation
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Would the project increase the
use of existing neighborhood and
regional parks, or other
recreational facilities such that
substantial physical deterioration
of the facility would occur or be
accelerated?
Less than
Significant None No No No Yes Yes
b. Does the project include
recreational facilities or require
the construction or expansion of
recreational facilities which might
have an adverse physical effect on
the environment?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 95 of 157
Previous CEQA Analysis Recreation Findings
The 2024 SEIR identified less than significant impacts associated with the provision of new or physically
altered parks, or the need for new or physically altered parks, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios or other performance
objectives (PS-4). The 2024 SEIR identified less than significant impacts related to the increase in use
of existing neighborhood and regional parks or other recreational facilities such that substantial
physical deterioration of the facility would occur or be accelerated and for including recreational
facilities or requiring the construction or expansion of recreational facilities which might have an
adverse physical effect on the environment (PS-4) (Section 4.12, Public Services and Recreation).
Addendum Analysis
The CAP Update would not generate new or increased demand for parks and recreation facilities.
Typically, this impact occurs when a project induces population growth, such as new development or
a business that would necessitate a large number of new employees. The CAP Update does not include
development of new residences or the creation of substantial numbers of permanent jobs. Therefore,
implementation of the CAP Update would not result in substantial adverse physical impacts associated
with the provision of new or physically altered park facilities. Implementation of the CAP Update would
also not increase the use of recreational facilities to the extent that substantial deterioration would
occur or require the construction or expansion of recreational facilities.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to recreation. The 2024 SEIR did not identify
significant recreation impacts and did not identify mitigation measures. The CAP Update would not
result in any new or substantially more severe significant impacts related to recreation. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to
recreation.
Oct. 2, 2024 Item #1 96 of 157
Transportation
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Conflict with a program, plan,
ordinance or policy addressing
the circulation system, including
transit, roadway, bicycle and
pedestrian facilities?
Less than
Significant None No No No Yes Yes
b. Conflict or be inconsistent with
CEQA Guidelines § 15064.3,
subdivision (b)?
Significant
and
Unavoidable
MM T-1 No No No Yes Yes
c. Substantially increase hazards
due to a geometric design
feature ((e.g., sharp curves or
dangerous intersections) or
incompatible uses (e.g., farm
equipment)
Less than
Significant None No No No Yes Yes
d. Result in inadequate emergency
access?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 97 of 157
Previous CEQA Analysis Transportation Findings
The 2024 SEIR identified a less than significant impact for conflicts with a program, plan, ordinance or
policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities
(T-1). The 2024 SEIR identified that although mitigation measure T-1 would aim to achieve VMT
reductions for development projects, it concluded impacts to be significant and unavoidable related
to CEQA Guidelines Section 15064.3, subdivision (b) (T-2). The 2024 SEIR identified a less than
significant impact related to substantially increasing hazards due to a geometric design feature (T-3)
and for inadequate emergency access (T-4) (Section 4.13, Transportation).
Addendum Analysis
Overall, implementation of the CAP Update (e.g., Measures T-1 through T-7 and T-10) would result in
lower total annual VMT levels in the city. However, short-term construction activities associated with
the CAP Update would lead to minor, temporary disruptions to traffic circulation patterns during the
period of construction. Projects that would require construction include retrofitting of existing
buildings and developments to transition to higher energy efficiency and renewable energy generation
(Measures E-1, E-6, W-1, and W-2), constructing roundabouts or traffic circles (Measure T-1),
installation of solar carports (Measure E-3.3), installation of zero emission vehicle charging stations
(Measure T-8), improvements to pedestrian and bicycling infrastructure (Measures T-5 and T-4), and
implementation of activities related to urban tree planting (Measure CS-1).
Long-term transportation changes could result from actions aimed at diverting and eliminating solid
waste; for example, generation of more compostable materials and demand for compost products
(Measure WD-1) would lead to a need for haul trucks to transport these materials. Truck trips for hauling
of organic waste to processing facilities would be offset by reductions in truck trips to landfills. Organic
waste collected in the city is recycled at a Republic Services composting facility in Otay (City of Carlsbad
2024). Other long-term transportation changes associated with the CAP Update could result from actions
that increase transit use and reduce commuting and traffic congestion. Actions such as increasing the
number of roundabouts or traffic circles (Measure T-1), and incentivizing people to use alternative modes
of travel (Measures T-2 and T-8) would lead to reduced traffic congestion. Changes to circulation patterns
for pedestrian and cycling mobility modes would result from implementation of new pedestrian and
bicycling routes, as well as enhancement of existing infrastructure (e.g., adding lanes, buffers, and
sidewalks). Implementation of the CAP Update would improve the operation of the circulation system in
several ways, including fewer vehicle trips on roadways and highways and higher numbers of transit
riders. Therefore, implementation of the CAP Update would not adversely affect the performance of the
circulation system and would not conflict with any applicable transportation plans, ordinances, or policies.
Implementation of the CAP Update would not induce substantial population or employment growth in
the city that would in turn generate increased VMT. Construction activities associated with the CAP
Update measures and actions would not require a large construction crew. Any temporary VMT
increases associated with construction activities would be more than offset by the CAP Update’s overall
effect of reducing the long-term rate of VMT in the city. Therefore, CAP Update implementation would
not conflict or be inconsistent with CEQA Guidelines section 15064.3(b). SEIR mitigation measure T-1,
which would reduce VMT levels of housing development identified in the SEIR, is not applicable to the
CAP Update because the CAP Update would result in decreased levels of VMT in the city.
The city maintains improvement standards that guide the construction of new transportation facilities
to minimize design hazards for all users of the system. Furthermore, General Plan policies 3-P.10, 3-
P.12, 3-P.13, and 3-P.16 would reduce impacts related to safety. Therefore, implementation of the
CAP Update would not substantially increase hazards due to a geometric design feature.
Oct. 2, 2024 Item #1 98 of 157
In the short-term, implementation of the CAP Update would have the potential to affect emergency
access during construction of individual projects facilitated by the CAP Update. For example,
construction pertaining to improving pedestrian and bicycle infrastructure and safety (Measures T-4 and
T-5) could temporarily alter existing roadways that serve as emergency access routes. In the long-term,
the CAP Update would not result in new development or land uses that would require installation of
emergency access routes. Activities implementing the CAP Update would not be permitted to conflict
with regulatory requirements to provide adequate accommodation of fire access to structure frontages,
multiple access points to development, as well as adequate width, height, and turning radius of roadways
and access points, pursuant to California Building Code and California Fire Code requirements. Activities
implementing the CAP Update would be required to comply with city and San Diego County standards
and requirements and would undergo review by public safety officials as part of the approval process.
Additionally, General Plan policies 3-P.12, 3-P.29, 3-P.30, and 3-P.33 would prevent CAP update
implementation from resulting in physical effects that impede or obstruct emergency access. Therefore,
implementation of the CAP Update would not result in inadequate emergency access.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to transportation. Implementation of Mitigation
Measure T-1 from the 2024 SEIR is not applicable to the CAP Update. The CAP Update would not result
in any new or substantially more severe significant impacts related to transportation. Applicable Mitigation Measures from the SEIR
The 2024 SEIR identified Mitigation Measure T-1 for transportation impact T-2. This mitigation
measure is not applicable to the CAP Update.
Oct. 2, 2024 Item #1 99 of 157
Tribal Cultural Resources
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information of
Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Would the project cause a
substantial adverse change in the
significance of a tribal cultural
resource, defined in Public
Resources Code §21074 as either
a site, feature, place cultural
landscape that is geographically
defined in terms of the size and
scope of the landscape, sacred
place, or object with cultural
value to a California Native
American tribe, and that is:
i. Listed or eligible for listing in
the California Register of
Historical Resources, or in a
local register of historical
resources as defined in
Public Resources Code
section 5020.1(k), or
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 100 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance Conclusion
SEIR
Mitigation Measures
Do the Proposed
Changes Involve
a New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Are There New
Circumstances
Involving a New or Substantial
Increase in the
Severity of
Previously
Identified Impacts?
Is There New
Information of Substantial
Importance
Requiring
New Analysis
or Verification?
Are Only Minor
Technical Changes
or Additions Necessary or Did
None of the
Conditions
Described in
§15162 Occur? (§15164(a))
Project is
within the
Scope of the SEIR?
ii. A resource determined by
the lead agency, in its
discretion and supported by
substantial evidence, to be
significant pursuant to
criteria set forth in
subdivision c of Public
Resources Code §5024.1, the
lead agency shall consider
the significance of the
resource to a California
Native American tribe.
Oct. 2, 2024 Item #1 101 of 157
Previous CEQA Analysis Tribal Cultural Resources Findings
The 2024 SEIR identified less than significant impacts related to causing a substantial adverse change
in the significance of a Tribal cultural resource as defined in Public Resources Code Section 21074
that is listed or eligible for listing in the California Register of Historical Resources, or in a local
register of historical resources as defined in Public Resources Code Section 5020.1(k) or pursuant to
criteria set forth in subdivision (c) of Public Resources Code Section 5024.1 (CUL-4) (Section 4.4,
Cultural and Tribal Cultural Resources).
Addendum Analysis
Implementation of the CAP Update would result in physical changes to the environment that could
occur in proximity to or involve encountering tribal cultural resources. For example, some
improvements that result from the CAP Update, such as Measures T-1, T-4, T-5, T-8, T-9, CS-1, E-3.3, W-
1, and W-2, would require ground disturbing activities, including minor grading and excavation, during
which, depending on their location, a tribal cultural resource could be encountered. The Carlsbad
Cultural Resource Guidelines addresses identification and treatment of tribal cultural resources that
may be impacted as a result of the CAP Update. Therefore, implementation of the CAP Update would
not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a
California Native American tribe, and that is listed or eligible for listing in the California Register of
Historical Resources, or in a local register of historical resources as defined in Public Resources Code
section 5020.1(k). Since the CAP Update would adhere to the Carlsbad Cultural Resource Guidelines, it
would not cause a substantial adverse change in the significance of a tribal cultural resource, pursuant
to criteria set forth in subdivision (c) of Public Resources Code §5024.1.
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to tribal cultural resources. The 2024 SEIR did not
identify significant tribal cultural resources impacts and did not identify mitigation measures. The CAP
Update would not result in any new or substantially more severe significant impacts related to tribal
cultural resources. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to tribal
cultural resources.
Oct. 2, 2024 Item #1 102 of 157
Utilities and Service Systems
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Require or result in the
relocation or construction of new or expanded water, wastewater
treatment or storm water drainage, electric power, natural
gas, or telecommunications facilities, the construction or
relocation of which could cause significant environmental
effects?
Less than
Significant None No No No Yes Yes
b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 103 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
c. Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Less than
Significant None No No No Yes Yes
d. Generate solid waste in excess
of State or local standards, or
in excess of the capacity of
local infrastructure, or
otherwise impair the
attainment of solid waste
reduction goals?
Less than
Significant None No No No Yes Yes
e. Comply with federal, State,
and local management and
reduction statutes and
regulations related to solid
waste?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 104 of 157
Previous CEQA Analysis Utilities and Service Systems Findings
The 2024 SEIR identified less than significant impacts related to the relocation or construction of new
or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or
telecommunication facilities (UTIL-1); sufficient water supplies during normal, dry and multiple dry
years (UTIL-2); adequate wastewater treatment capacity (UTIL-3); the generation of solid waste in
excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise
impair the attainment of solid waste reduction goals and compliance with federal, State, and local
management and reduction statutes and regulations related to solid waste (UTIL-4) (Section 4.14,
Utilities and Service Systems).
Addendum Analysis
Implementation of the CAP Update would not increase development or induce population growth
directly or indirectly, because measures and actions do not propose new housing nor do they propose
changes to policies or regulations related to land use or residential or nonresidential zoning. Although
tree planting (Measure CS-1) would potentially increase demand for water used for irrigation, the CAP
Update would be required to comply with General Plan policies 9-P.3 through 9-P.6, which would
reduce impacts to water services and facilities by promoting water saving measures such as water sub-
metering, using recycled water for landscape irrigation, and using on-site gray water and rainwater
collection systems. Therefore, the CAP Update would not result in demand for new or expanded
infrastructure, including water, wastewater treatment, stormwater drainage, natural gas or
telecommunication facilities would not increase to serve new population or development.
The implementation of the CAP Update would incrementally increase electricity consumption, for
example through measures that increase the installation zero emission infrastructure (Measure T-8),
consume energy more efficiently within buildings and water systems (Measures E-3.1, E-3.2, E-4.2 E-
6, and W-2), and install solar carports (Measure E-3.3). However, as discussed in the San Diego Gas and
Electric Company (SDG&E)’s Integrated Resource Plan, SDG&E has existing plans in place to solicit
additional long-term renewable contracts, including conventional and long-duration storage
technologies (SDG&E 2022). The CAP Update’s support for using more renewable energy and more
efficient natural gas consumption would decrease demand for natural gas infrastructure.
The implementation of the CAP Update would not involve development of residential communities or
other non-residential development or induce population growth in an area that would increase
demand for wastewater treatment. Further, it would not involve the construction of restroom
facilities. Implementation of the CAP Update would not result in new habitable structures (e.g.,
housing, nonresidential development) that would generate wastewater, therefore, implementation of
the CAP Update would not exceed the capacity of any wastewater treatment provider.
Implementation of the CAP Update would not induce increased residential or non-residential
development, or population growth directly or indirectly, and there would be no increase in solid
waste production as a result of the CAP Update. Although some solid waste could be generated during
construction activities or through retrofitting buildings (Measure E-6), the solid waste generated
would be minimal due to the nature of construction activities and associated improvements, and
therefore would not exceed the capacity of local facilities. Measure WD-1 includes strategies to
continue to increase the diversion of waste from landfills, which is consistent with and would further
State solid waste statutes and goals Therefore, solid waste generated as a result of the CAP Update
would not be generated in excess of local standards or capacity of local infrastructure.
Oct. 2, 2024 Item #1 105 of 157
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to utilities and service systems. The 2024 SEIR did
not identify significant utilities and service systems impacts and did not identify mitigation measures.
The CAP Update would not result in any new or substantially more severe significant impacts related
to utilities and service systems. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to utilities
and service systems.
Oct. 2, 2024 Item #1 106 of 157
Wildfire
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the Proposed
Changes Involve
a New or
Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances
Involving a New
or Substantial
Increase in the
Severity of
Previously
Identified
Impacts?
Is There New
Information
of Substantial
Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical Changes
or Additions
Necessary or Did
None of the
Conditions
Described in
§15162 Occur?
(§15164(a))
Project is
within the
Scope of
the SEIR?
Would implementation of the CAP Update:
a. Substantially impair an adopted
emergency response plan or
emergency evacuation plan?
Less than
Significant None No No No Yes Yes
b. Due to slope, prevailing winds, and
other factors, exacerbate wildfire
risks, and thereby expose project
occupants to pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire?
Less than
Significant None No No No Yes Yes
c. Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
brakes, emergency water sources,
power lines or other utilities) that
may result in temporary or ongoing
impacts to the environment?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 107 of 157
CEQA Guidelines Section 15162
Is a Subsequent SEIR Needed?
SEIR Evaluation Criteria
SEIR
Significance
Conclusion
SEIR
Mitigation
Measures
Do the
Proposed
Changes
Involve a New
or Substantial Increase in the
Severity of
Previously
Identified
Impacts?
Are There New
Circumstances Involving a
New or Substantial Increase
in the Severity of Previously
Identified Impacts?
Is There New
Information
of Substantial Importance
Requiring
New Analysis
or
Verification?
Are Only Minor
Technical
Changes or
Additions
Necessary or Did None of
the Conditions
Described in
§15162 Occur?
(§15164(a))
Project is within
the
Scope of
the
SEIR?
d. Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
Less than
Significant None No No No Yes Yes
Oct. 2, 2024 Item #1 108 of 157
Previous CEQA Analysis Wildfire Findings
The 2024 SEIR identified less than significant impacts for wildfire emergency response, access, and
evacuation (WF-1); and related to slope, prevailing winds, and other factors that could exacerbate
wildfire risks, installation or maintenance of associated infrastructure that may exacerbate fire risk or
that may result in temporary or ongoing impacts to the environment, exposing people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-
fire slope instability, or drainage changes; and exposing people or structures, either directly or indirectly,
to a significant risk of loss, injury, or death involving wildland fires (WF-2) (Section 4.15, Wildfire).
Addendum Analysis
The implementation of the CAP Update would result in short-term and long-term changes related to wildfire as described below.
Implementation of the CAP Update would result in alterations of public roadways. The CAP Update measures and actions would include improvements at or near grade level of existing roadways, new and upgraded bikeways and walkways along existing developed roadways and rights-of-way in the city, and the installation of roundabouts or traffic circles to control traffic within the intersections of existing developed roadways (through implementation of Measures T-1, T-4, T-5, and T-8). However, these improvements would not adversely affect the capacity of roadways during an emergency or evacuation. New Class II bike lanes and Class II buffered bike plans implemented per Measure T-4
would be separately from vehicle lanes using paint and therefore would not impede the movement of emergency vehicles or vehicles during an evacuation event. CAP Update Measure T-1, which encourages the installation of roundabouts, would reduce congestion, thus increasing traffic flow and
the ability to evacuate during an emergency. Therefore, implementation of the CAP Update would not impair or interfere with adopted emergency response or evacuation plans.
Although the city is located within a Local Responsibly Area Very High Fire Hazard Severity Zone and
adjacent to a State Responsibility Area Very High Fire Hazard Severity Zone, the CAP Update measures and actions would not include the construction of new housing and do not propose changes to policies or regulations related to land use or residential zoning. The CAP Update would not introduce new
occupants that could be exposed to pollutant concentrations from a wildfire or the uncontrolled spread of as wildfire or require the installation or maintenance of associated infrastructure (such as roads, fuel brakes, emergency water sources, power lines or other utilities). Action CS-1.a would
continue implementation of the existing Community Forest Management Plan and therefore the CAP Update would not result in changes to the types of trees planted within fire hazard severity zones. Furthermore, activities associated with implementation of the CAP Update measures would comply
with the San Diego County Emergency Operations Plan (EOP) and be subject to the California Fire Code (CFC), which includes safety measures to minimize the threat of fire. Implementation of the CAP Update would also be required, where applicable, to meet CBC requirements, including CCR Title 24,
Part 2, which includes specific requirements related to exterior wildfire exposure. Impacts related to downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes would be reduced by compliance with the CBC and CMC, as well as applicable
policies from the Public Safety Element Update (policies 6-P.20 through 6-P.31). Compliance with applicable policies, codes and regulations would reduce the risk of loss, injury, or death from wildfire and the CAP Update would not exacerbate wildfire risks.
Oct. 2, 2024 Item #1 109 of 157
Conclusion
There are no changes in circumstances or new information of substantial importance that would
require major revisions to the 2024 SEIR or result in new significant effects or a substantial increase in
the severity of previously identified effects related to wildfire. The 2024 SEIR did not identify significant
wildfire impacts and did not identify mitigation measures. The CAP Update would not result in any
new or substantially more severe significant impacts related to wildfire. Applicable Mitigation Measures from the SEIR
There are no mitigation measures from the 2024 SEIR identified to reduce impacts related to wildfire.
Oct. 2, 2024 Item #1 110 of 157
7 References
California Department of Conservation. 2024. California Williamson Act Enrollment Finder. Available: https://gis.conservation.ca.gov/portal/home/webmap/viewer.html?webmap=18f7488c0a9d4d299f5e9c33b312f312. Retrieved March 28, 2024.
City of Carlsbad. 2015. City of Carlsbad General Plan Draft Environmental Impact Report. Available: https://www.carlsbadca.gov/departments/community-development/planning/general-plan/related-documents/-folder-773. Accessed March 20, 2024.
_________. 2020. An Addendum to the Previously Certified Program Environmental Impact Report for the 2015 General Plan Update and Climate Action Plan (PEIR 13-02). Available: https://records.carlsbadca.gov/WebLink/DocView.aspx?id=5154824&dbid=0&repo=CityofCarlsbad. Accessed April 15, 2024.
_________. 2021. 2021 Housing Element Update Addendum. Available: https://records.carlsbadca.gov/WebLink/DocView.aspx?id=5312802&dbid=0&repo=CityofCarlsbad&cr=1.Accessed April 15, 2024.
_________. 2023. City of Carlsbad Housing Element Implementation and Public Safety Element Update Draft Supplemental Environmental Impact Report. Available: https://files.ceqanet.opr.ca.gov/281700-3/attachment/_PFNFkSV8FCkmdU1hXlW25tF98n-BZ_pdzLkWZUQ3Kc2CA6Q1LZ_Xp9kUhHB0NSwdr7p4ccqp_dRZJ4S0. Accessed March 20, 2024.
_________. 2024. Organic Waste Composting. Available: https://www.carlsbadca.gov/departments/environmental-sustainability/reduce-reuse-recycle/organic-waste-recycling. Accessed April 15, 2024.
DOC. See California Department of Conservation.
San Diego Gas and Electric Company. 2022. Individual Integrated Resource Plan of San Diego Gas & Electric Company. Available: https://www.sdge.com/sites/default/files/regulatory/SDG%26E%202022%20Individual%20Integrated%20Resource%20Plan%20%28PUBLIC%29_0.pdf. Accessed March 28, 2024.
SDG&E. See San Diego Gas and Electric Company.
Oct. 2, 2024 Item #1 111 of 157
Exhibit 2
Oct. 2, 2024 Item #1 112 of 157
PLANNING COMMISSION RESOLUTION NO. 7521
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD,
CALIFORNIA, RECOMMENDING ADOPTION OF A CLIMATE ACTION PLAN
UPDATE AS AMENDED FROM THE PUBLICLY POSTED DRAFT SO THAT THE
MEASURES MEET THE REQUIRED 2045 REDUCTION TARGET AND EXCLUDES
MEASURES E-3.2, NONRESIDENTIAL BUILDING ENERGY -UPDATED REACH
CODE, E-3.3, NONRESIDENTIAL BUILDING ENERGY-SOLAR CARPORTS, AND
E-4.2, RESIDENTIAL BUILDING ENERGY -UPDATED REACH CODE
CASE NAME: CLIMATE ACTION PLAN UPDATE
CASE NO: N/A
WHEREAS, the City of Carlsbad was one of the first cities in the county to adopt a qualified
Climate Action Plan that outlined strategies and policies to reduce greenhouse gas emissions; and
WHEREAS, since then, communitywide greenhouse gas inventories and statewide targets have
been updated, presenting the opportunity for the city to update its Climate Action Plan and further
pursue the community's goal of promoting a sustainable environment; and
WHEREAS, the purpose of the Climate Action Plan Update is to describe how greenhouse gas
emissions within the City of Carlsbad will be reduced in accordance with state targets; and
WHEREAS, the city prepared a 2016 greenhouse gas inventory and forecast to inform the
Climate Action Plan Update; and
WHEREAS, based on the 2016 inventory, emissions forecasts, and suite of reduction measures,
the statewide reduction targets for 2035, derived from Senate Bill 32, and 2045, derived from Assembly
Bill 1279, can be met through implementation of the Climate Action Plan Update; and
WHEREAS, on Jan. 30, 2024, the City Council certified the Supplemental Environmental Impact
Report for the General Plan Land Use and Community Design Element and Public Safety Element (EIR
2022-0007); and
WHEREAS, an addendum to EIR 2022-0007 was prepared and indicated no significant
environmental impacts would occur as a result of implementing the Climate Action Plan Update; and
WHEREAS, the city posted a public draft of the Climate Action Plan Update to its website on July
8,2024;and
WHEREAS, the Planning Commission recommend changes to the publicly posted Draft Climate
Action Plan Update so that the measures meet the required 2045 reduction target; and
WHEREAS, these changes would be so that the following three measures would be excluded in
the Climate Action Plan Update: E-3.2, Nonresidential Building Energy -Updated Reach Code, E-3.3,
Oct. 2, 2024 Item #1 113 of 157
Nonresidential Building Energy -Solar Carports, and E-4.2, Residential Building Energy -Updated
Reach Code.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
A) That the above recitations are true and correct.
B) Record and basis for action. The Planning Commission has considered the full record
before it, which includes the Record of Proceedings. Furthermore, the recitals set forth
above are found to be true and correct and material to this resolution; and are
incorporated herein by reference.
C) That based on the evidence presented at the public hearing, the Commission
RECOMMENDS ADOPTION of a Climate Action Plan Update as amended from the
publicly posted draft, Attachment A, so that measures meet the required 2045
reduction target and excludes the following measures: E-3.2, Nonresidential Building
Energy -Updated Reach Code, E-3.3, Nonresidential Building Energy -Solar Carports,
and E-4.2, Residential Building Energy-Updated Reach Code
PASSED, APPROVED AND ADOPTED at a regular meeting of the Planning Commission of the City
of Carlsbad on the Oct. 2, 2024, by the following vote, to wit:
AYES: Hubinger, Meenes, Merz, Stine
NAYES: Kamenjarin, Lafferty, Danna
ABSENT: None.
ABSTAIN: None.
WILLIAM KAMENJAR N, Chairperson
CARLSBAD PLANNING COMMISSION
ATTEST:
ERIC LARDY
City Planner
Draft Climate Action Plan found on City Website:
Draft Climate Action Plan
AND
Sept. 4, 2024, Planning Commission staff report
(on file in the office of the City Clerk)
Oct. 2, 2024 Item #1 114 of 157
PLANNING COMMISSION RESOLUTION NO.
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD,
CALIFORNIA, RECOMMENDING ADOPTION OF THE PUBLICLY POSTED DRAFT
CLIMATE ACTION PLAN UPDATE, EXCLUDING MEASURE E-3.2
(NONRESIDENTIAL BUILDING ENERGY – UPDATED REACH CODE), WHICH
WOULD EXCEED THE 2045 REDUCTION TARGET BY APPROXIMATELY 200 MT
CO2E
CASE NAME: CLIMATE ACTION PLAN UPDATE
CASE NO: N/A
WHEREAS, the City of Carlsbad was one of the first cities in the county to adopt a qualified
Climate Action Plan that outlined strategies and policies to reduce greenhouse gas emissions; and
WHEREAS, since then, communitywide greenhouse gas inventories and statewide targets have
been updated, presenting the opportunity for the city to update its Climate Action Plan and further
pursue the community’s goal of promoting a sustainable environment; and
WHEREAS, the purpose of the Climate Action Plan Update is to describe how greenhouse gas
emissions within the City of Carlsbad will be reduced in accordance with state targets; and
WHEREAS, the city prepared a 2016 greenhouse gas inventory and forecast to inform the
Climate Action Plan Update; and
WHEREAS, based on the 2016 inventory, emissions forecasts, and suite of reduction measures,
the statewide reduction targets for 2035, derived from Senate Bill 32, and 2045, derived from Assembly
Bill 1279, can be met through implementation of the Climate Action Plan Update; and
WHEREAS, on Jan. 30, 2024, the City Council certified the Supplemental Environmental Impact
Report for the General Plan Land Use and Community Design Element and Public Safety Element (EIR
2022-0007); and
WHEREAS, an addendum to EIR 2022-0007 was prepared and indicated no significant
environmental impacts would occur as a result of implementing the Climate Action Plan Update; and
WHEREAS, the city posted a public draft of the Climate Action Plan Update to its website on July
8, 2024; and
WHEREAS, the Planning Commission recommended changes to the publicly posted Draft
Climate Action Plan Update that still exceeded the 2045 reduction target, but by a different amount
from what is included in the public Draft; and
Oct. 2, 2024 Item #1 115 of 157
Exhibit 3
WHEREAS, the Planning Commission recommended adoption of the publicly posted Draft
Climate Action Plan Update, excluding Measure E-3.2, Nonresidential Building Energy – Updated Reach
Code, which would exceed the 2045 reduction target by approximately 200 MT CO2e.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as
follows:
A)That the above recitations are true and correct.
B)Record and basis for action. The Planning Commission has considered the full record
before it, which includes the Record of Proceedings. Furthermore, the recitals set forth
above are found to be true and correct and material to this resolution; and are
incorporated herein by reference.
C)That based on the evidence presented at the public hearing, the Commission
RECOMMENDS ADOPTION of a Climate Action Plan Update as amended from the
publicly posted draft, Attachment A, excluding Measure E-3.2 (Nonresidential Building
Energy – Updated Reach Code), which would exceed the 2045 reduction target by
approximately 200 MT CO2e.
PASSED, APPROVED AND ADOPTED at a regular meeting of the Planning Commission of the City
of Carlsbad on the Oct. 2, 2024, by the following vote, to wit:
AYES:
NAYS:
ABSENT:
ABSTAIN:
_______________________________
BILL KAMENJARIN, Chairperson
CARLSBAD PLANNING COMMISSION
ATTEST:
______________________________
ERIC LARDY
City Planner
Oct. 2, 2024 Item #1 116 of 157
PLANNING COMMISSION RESOLUTION NO.
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD,
CALIFORNIA, RECOMMENDING ADOPTION OF THE PUBLICLY POSTED DRAFT
CLIMATE ACTION PLAN UPDATE, EXCLUDING MEASURE E-4.2 (RESIDENTIAL
BUILDING ENERGY – UPDATED REACH CODE), WHICH WOULD EXCEED THE
2045 REDUCTION TARGET BY APPROXIMATELY 4,000 MT CO2E
CASE NAME: CLIMATE ACTION PLAN UPDATE
CASE NO: N/A
WHEREAS, the City of Carlsbad was one of the first cities in the county to adopt a qualified
Climate Action Plan that outlined strategies and policies to reduce greenhouse gas emissions; and
WHEREAS, since then, communitywide greenhouse gas inventories and statewide targets have
been updated, presenting the opportunity for the city to update its Climate Action Plan and further
pursue the community’s goal of promoting a sustainable environment; and
WHEREAS, the purpose of the Climate Action Plan Update is to describe how greenhouse gas
emissions within the City of Carlsbad will be reduced in accordance with state targets; and
WHEREAS, the city prepared a 2016 greenhouse gas inventory and forecast to inform the
Climate Action Plan Update; and
WHEREAS, based on the 2016 inventory, emissions forecasts, and suite of reduction measures,
the statewide reduction targets for 2035, derived from Senate Bill 32, and 2045, derived from Assembly
Bill 1279, can be met through implementation of the Climate Action Plan Update; and
WHEREAS, on Jan. 30, 2024, the City Council certified the Supplemental Environmental Impact
Report for the General Plan Land Use and Community Design Element and Public Safety Element (EIR
2022-0007); and
WHEREAS, an addendum to EIR 2022-0007 was prepared and indicated no significant
environmental impacts would occur as a result of implementing the Climate Action Plan Update; and
WHEREAS, the city posted a public draft of the Climate Action Plan Update to its website on July
8, 2024; and
WHEREAS, the Planning Commission recommended changes to the publicly posted Draft
Climate Action Plan Update that still exceeded the 2045 reduction target, but by a different amount
from what is included in the public Draft; and
Oct. 2, 2024 Item #1 117 of 157
Exhibit 4
WHEREAS, the Planning Commission recommended adoption of the public Draft Climate Action
Plan Update, excluding Measure E-4.2 (Residential Building Energy – Updated Reach Code), which
would exceed the 2045 reduction target by approximately 4,000 MT CO2e.
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City of Carlsbad,
California, as follows:
A)That the above recitations are true and correct.
B)Record and basis for action. The Planning Commission has considered the full record
before it, which includes the Record of Proceedings. Furthermore, the recitals set forth
above are found to be true and correct and material to this resolution; and are
incorporated herein by reference.
C)That based on the evidence presented at the public hearing, the Commission
RECOMMENDS ADOPTION of a Climate Action Plan Update as amended from the
publicly posted draft, Attachment A, excluding Measure E-4.2 (Residential Building
Energy – Updated Reach Code), which would exceed the 2045 reduction target by
approximately 4,000 MT CO2e.
PASSED, APPROVED AND ADOPTED at a regular meeting of the Planning Commission of the City
of Carlsbad on the Oct. 2, 2024, by the following vote, to wit:
AYES:
NAYS:
ABSENT:
ABSTAIN:
_______________________________
BILL KAMENJARIN, Chairperson
CARLSBAD PLANNING COMMISSION
ATTEST:
______________________________
ERIC LARDY
City Planner
Oct. 2, 2024 Item #1 118 of 157
PLANNING COMMISSION RESOLUTION NO.
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF CARLSBAD,
CALIFORNIA, RECOMMENDING ADOPTION OF THE PUBLICLY POSTED DRAFT
OF THE CLIMATE ACTION PLAN UPDATE, WHICH WOULD EXCEED THE 2045
REDUCTION TARGET BY APPROXIMATELY 6,000 MT CO2E
CASE NAME: CLIMATE ACTION PLAN UPDATE
CASE NO: N/A
WHEREAS, the City of Carlsbad was one of the first cities in the county to adopt a qualified
Climate Action Plan that outlined strategies and policies to reduce greenhouse gas emissions; and
WHEREAS, since then, communitywide greenhouse gas inventories and statewide targets have
been updated, presenting the opportunity for the city to update its Climate Action Plan and further
pursue the community’s goal of promoting a sustainable environment; and
WHEREAS, the purpose of the Climate Action Plan Update is to describe how greenhouse gas
emissions within the City of Carlsbad will be reduced in accordance with state targets; and
WHEREAS, the city prepared a 2016 greenhouse gas inventory and forecast to inform the
Climate Action Plan Update; and
WHEREAS, based on the 2016 inventory, emissions forecasts, and suite of reduction measures,
the statewide reduction targets for 2035, derived from Senate Bill 32, and 2045, derived from Assembly
Bill 1279, can be met through implementation of the Climate Action Plan Update; and
WHEREAS, on Jan. 30, 2024, the City Council certified the Supplemental Environmental Impact
Report for the General Plan Land Use and Community Design Element and Public Safety Element (EIR
2022-0007); and
WHEREAS, an addendum to EIR 2022-0007 was prepared and indicated no significant
environmental impacts would occur as a result of implementing the Climate Action Plan Update; and
WHEREAS, the city posted a public draft of the Climate Action Plan Update to its website on July
8, 2024.
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City of Carlsbad,
California, as follows:
A)That the above recitations are true and correct.
B)Record and basis for action. The Planning Commission has considered the full record
before it, which includes the Record of Proceedings. Furthermore, the recitals set forth
Oct. 2, 2024 Item #1 119 of 157
Exhibit 5
above are found to be true and correct and material to this resolution; and are
incorporated herein by reference.
C)That based on the evidence presented at the public hearing, the Commission
RECOMMENDS ADOPTION of the publicly posted draft of the CLIMATE ACTION PLAN
UPDATE.
PASSED, APPROVED AND ADOPTED at a regular meeting of the Planning Commission of the City
of Carlsbad on the Oct. 2, 2024, by the following vote, to wit:
AYES:
NAYS:
ABSENT:
ABSTAIN:
_______________________________
BILL KAMENJARIN, Chairperson
CARLSBAD PLANNING COMMISSION
ATTEST:
______________________________
ERIC LARDY
City Planner
Oct. 2, 2024 Item #1 120 of 157
Sept. 4, 2024, Planning Commission staff report
(on file in the office of the City Clerk)
Oct. 2, 2024 Item #1 121 of 157
Exhibit 6
Exhibit 7
Public feedback received on Draft Climate Action Plan Update as of Sept. 13, 2024.
Oct. 2, 2024 Item #1 122 of 157
From:Randi Greene
To:Katie Hentrich
Subject:Climate action plan
Date:Monday, July 8, 2024 5:47:47 PM
Please consider disallowing the burning of wood or debris at residential properties. It is destroying our
neighbourhood air quality.
Sent from my iPhone
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Oct. 2, 2024 Item #1 123 of 157
From:Gregg Ferry
To:Katie Hentrich
Subject:Climate Action Plan
Date:Thursday, July 11, 2024 2:12:03 PM
A couple of things I saw that was of interest.
Divest any investments that support fossil fuels. Only invest in funds, stocks,
bonds, etc. that guarantee they will not invest in fossil fuels.
Until electric utilities use no energy from fossil fuels, these investments should be on the listfor divestment, too.
4. Solar, Microgrids and Virtual Power Plants (VPP)
Not mentioned here was energy storage at the solar and Microgrid locations. This will makefor a more resilient community.
--
Gregg Ferry3344 Appian Rd
Carlsbad CA 92010(805) 743-3779
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Oct. 2, 2024 Item #1 124 of 157
From:Brian Magner
To:Katie Hentrich
Subject:Draft Climate Action Plan comment - Leaf Blower timeline
Date:Friday, July 12, 2024 12:38:51 PM
Katie -
Great to see the draft Climate Action plan. I'm proud of Carlsbad to be addressing
this, in a transparent way.
I am particularly glad to see leaf blowers being addressed, but am also wildly
disappointed to see the lack of action on the timeline. The California Air Resources
Board is requiring all new small off-road engines be zero emission by 2024, this year
(link). At least 25 cities across California and more than 100 nationwide have enacted
legislation to regulate or ban gas-powered leaf blowers, many cities much larger than
Carlsbad (Oakland, Beverly Hills, Santa Barbara). Encinitas banned gas powered leaf
blowers starting in Jan 2020 (>4 years ago!!). And yet Carlsbad hasn't. On top of that,
this plan proposes to develop a plan by 2030 and implement that plan by 2035.
There is a statement at the beginning of the Climate Action Plan report that states"The City of Carlsbad (city) strives to provide a clean and safe environment for
residents, workers and visitors by protecting natural resources and facing the
challenge of climate change head on. With these goals in mind, Carlsbad has
become a regional leader in climate action with early and sustained efforts to reduceits contribution to climate change.". The City's website indicates: "Environmental
sustainability is a key priority for City Council.".
If those statements were true, the timeline for banning gas powered leaf blowersshould be to develop a plan by the end of 2024 and implement that plan for no more
gas powered leaf blowers by 2025. The 2030 and 2035 timelines are a terrible failure
to take action on something that should be considered easy / "low hanging
fruit". There are dozens of implementation plan examples to pull from other cities.There are already state and local programs with incentives for landscapers to
transition to zero emissions equipment. My weekly landscaping company has already
voluntarily transitioned to battery powered backpack leaf blowers and I'd be happy to
share their name with anyone looking for a quieter landscaping company.
Carlsbad is already WAY behind so many other CA cities on this topic. It's false for
Carlsbad to declare itself a leader and not take action now, this year, to ban gas
powered leaf blowers. Please consider revising these targets.
Thanks,
Brian Magner
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Oct. 2, 2024 Item #1 125 of 157
From:Lynda Daniels
To:Keith Blackburn; Teresa Acosta; Priya Bhat-Patel; Carolyn Luna; melanieburkholder@carlsbadca.gov; KatieHentrich
Subject:Synthetic Turf - Carlsbad CAP
Date:Tuesday, July 16, 2024 8:04:56 PM
Please, no synthetic turf in our parks
Synthetic Turf and GHG’s
Synthetic turf is a major contributor to GHG’s throughout its lifecycle
and must be included in the CAP:
Manufacturing
Oil extraction/fracking, petrochemical refining and manufacturing
synthetic turf & underlayment pads all produce significant amounts of
GHG’s.
Use
Synthetic turf off-gases methane and other GHG’s during use, while
natural grass is a carbon sink.
End of Life
Fifty tons/acre of synthetic turf hazardous waste off-gases methane and
other GHG’s for up to 1000 years.
Replacing synthetic turf with natural grass provides significant
reductions in GHG’s and is clearly a climate issue.
Lynda
Oct. 2, 2024 Item #1 126 of 157
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Oct. 2, 2024 Item #1 127 of 157
From:Lynda Daniels
To:Katie Hentrich; Teresa Acosta; Priya Bhat-Patel; PD; Keith Blackburn; Carolyn Luna;melanieburkholder@carlsbadca.gov
Subject:CLIMATE ACTION PLAN COMMENTS
Date:Saturday, August 3, 2024 8:21:38 PM
CLIMATE ACTION PLAN COMMENTS
MAYOR, CITY COUNCIL AND KATIE,
I am very pleased with the draft of our CAP! It includes so many ways to help Carlsbad meet our
sustainability goals! In six different areas!! Very detailed and well done!
I have a few minor suggestions:
page 3-20 - add WORKSHOPS to be planned by staff to educate residents
page 3-21 - building efficiency can be improved by specific benchmarking ordinances - San Luis Obispo -
has a great one you can copy!
page 3-13 - Eliminate natural gas use at city facilities AT END OF LIFE ("FEASIBLE" IS TOO VAGUE)
Lastly, include ALL LAWN EQUIPMENT, not just leaf blowers in the phasing out goal!
Thank you for all the hard work the staff has done to make this CAP so good~
Lynda Daniels
4547 Picadilly Court
Carlsbad
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Oct. 2, 2024 Item #1 128 of 157
August 6, 2024
Ka.e Hentrich
Climate Ac.on Plan Administrator
City of Carlsbad
Sent via email
Subject: Comments on CAP Update
Dear Ms. Hentrich,
We appreciate the effort that has gone into this CAP update—building on the work of the past
while also responding to new requirements and changing condi.on.
We also realize that there is broad discre.on in selec.ng the ac.ons to reduce local GHG
emissions.
While there is much to commend in this document, our objec.ve with these comments is to
suggest areas where we think some modifica.ons would result in a more accurate analysis and
more effec.ve results.
Community Wide Emissions Inventory
-There are some interes.ng differences in comparing the current 2016 inventory results
to those from 2012 that were used for the prior CAP Update. While several of the
sectors increased as a percentage of total emissions, others decreased. Transporta.on
remains the largest single sector and is accoun.ng for an increasing share of total
emissions. Off road equipment showed a substan.al increase, more than doubling from
1.4% to 3 %. Since this is one of the hard data comparison points, it might be helpful to
add some comments about trend line, and does this demonstrate the amount of
progress that was an.cipated?
-Total emissions increased from 977,000 MT in 2012 to 981,000 MT in 2016- or about 1
MT/year. This rate of increase drops to an average of .6 MT/year for the period
2016-2035. It then makes a drama.c increase to 3.1 MT/year from 2035-2045. Is there
an explana.on for these differences?
5020 Nighthawk Way - Oceanside, CA 92056 www.preservecalavera.org
Nonprofit 501(c)3 ID#33-0955504
1
Oct. 2, 2024 Item #1 129 of 157
'Preserve Ca avera
Coastal North San Diego County
-It would be helpful to iden.fy what is excluded from the community inventory and
where those emissions would get counted. We believe that includes the airport and
Poseidon plant and there may be others.
-There is a clear statement that the city wants to set the example for sustainability
improvements. Yet there are several areas where the City has full control, but delays
ac.on un.l 2030 or later, for example, solar covers over city parking lots, fleet
replacement schedule and TDM for employees. Please consider using early city
adop.on as part of strategy to expand results throughout the city.
-It would be helpful to provide good baseline data for percentage of trips by each
transporta.on mode, and a monitoring system to track and report on this over .me.
This would help inform related ac.ons for bikes, pedestrians and transit and the overfall
TDM program. This puts the focus on results (increasing use of alterna.ve
transporta.on) and not just ac.ons (building x miles of Class 1 bike trails).
-For mul.ple ac.ons addressing building energy improvements, it is not clear which
ac.ons are just complying with changes to state Building Code, and those for which the
city is really going beyond the state requirements. These also focus very much on non-
residen.al buildings. While much of Carlsbad’s housing stock is rela.vely new, there
remains substan.al opportunity for reduced energy use form residen.al buildings.
Ac4on Items
WD-1 Solid and Organic Waste Diversion
We realize that this is an area that is going through recent changes to comply with new
state laws. The basic waste stream analysis was based on data for the city of Oceanside.
That showed the largest share of this waste comes from food and paper. It would be
desirable to target some ac.ons around these specific categories of waste. And to
develop local data to measure results. CalRecycle requires some standard repor.ng
which could form the basis for this.
T2- TDM
This is an area that has high poten.al benefit, much of which is not being realized. The
TDM ordinance is limited to new non-residen.al uses. Other places have expended such
programs to address all land uses, with different goals and measures targeted to each
land use. There is also tremendous opportunity to improve the use of alterna.ve
transporta.on by exis.ng businesses. While these may not be mandatory, at least
encouraging this, spotligh.ng those who are making progress, working with the
Chamber of Commerce to recognized program par.cipants could all start to both raise
awareness and par.cipa.on by the broader community. We encourage Carlsbad to take
a more comprehensive approach to TDM.
2
Oct. 2, 2024 Item #1 130 of 157
T-4 Bikeway system Improvements
Seems like ac.on T-4.e to explore microtransit does not belong here.
T-6 Transporta.on System Improvements
This men.ons the Mul.-Modal TIF’s that are s.ll being developed but includes no bench
marks and no quan.fica.on. While it is premature to quan.fy results, clearly
comple.ng this study is a key benchmark that should be included.
T.9 ZEV
Delaying restric.ons on city fleet idling un.l 2030 is another area where the city could
be an early adopter. But beyond that there is value to more compressive idling
ordinances and enforcement.
T-10 Parking Management
This men.ons the parking studies underway for the Village, Beach and Barrio but with
no benchmarks. Adding benchmarks for comple.on of these studies would bel er
integrate these ac.ons with the CAP.
OR-1 Off Road Equipment
The city could set an example here by adding an ac.on to require conversion of all city
equipment and mandate on city contractors to also eliminate gas powered leaf blowers.
Also leaf blowers are a small percentage of this category. There would be value to
include some ac.ons for those that are larger sources- construc.on and industrial.
CS-1 Carbon Sequestra.on
The inventory and ac.on focuses only on city owned trees. It is unknown what % of the
total tree canopy that these city trees represent. But the tree canopy cover (TCC) is a
city-wide measure that includes all of the non-city owned trees. The descrip.on should
also note the tree plan.ng program in Carlsbad schools. To make real progress on the
city wide TCC it is essen.al to also include all of the non-city owned trees. Key ac.ons
should include project condi.ons to increase the number of trees and require their
replacement, as well as enforcement of condi.ons to maintain and replace trees that
were part of an approved landscaping plan, especially within areas with HOA’s.
The City also has earned the designa.on of a Tree City, and should include maintaining
that as part of their ac.ons.
Monitoring and Repor4ng
We would like to see the city establish a Sustainability Commission that could provide input, and
expand the city’s reach for the CAP and other sustainability programs.
3
Oct. 2, 2024 Item #1 131 of 157
Quan4fica4on – Appendix C
-Electricity Table 6- It is not clear how the city specific emission factor of 545 lbs CO₂/
MWH was determined – and this is key to all of the other computa.ons and appears to
be the only city specific quan.fier.
-Off road equipment- It is clear that leaf blowers account for a small percentage of the
total off-road vehicle emissions-yet this is the only one targeted in CAP ac.ons. It
would be good to work toward the other sources like industrial in future updates.
-T-6 Transporta.on system improvements is based on 53 intersec.ons having signals
synchronized but the benchmark for the ac.on item only shows 20 intersec.ons. These
need to be consistent.
-T-2 TDM quan.fica.on does not seem to be consistent with the ac.on item in the CAP
or growth projec.ons used elsewhere in the Appendix. Table 23 shows 22k new
commuters with 40% of trips using alterna.ve transporta.on with 26 mi/RT for 255
days/year for a VMT reduc.on of 70,983,251 by 2045. But Table 2 shows jobs increase
19,139, not 22k. With 40 % alterna.ve transporta.on and same trip length and days
that is only a reduc.on of 49,764,000 VMT.
-T-3 Safe Routes to School is based on city of San Diego data with an average 1 mi RT to
walk and 2.5 miles to bike to school. But Carlsbad high schools do not have boundaries
and we would expect the average trip lengths are much longer than what was used.
-T-5 Pedestrian System (and bike system improvements). Demographics show an aging
popula.on with fewer of school age and high increases in the over 65 yr old age groups.
It would seem these changes in demographics would tend to reduce walking and biking
trips and that is not reflected in the quan.fica.on.
Thank you for considering our comments.
Sincerely,
Diane Nygaard, President
On behalf of Preserve Calavera
4
Oct. 2, 2024 Item #1 132 of 157
August 12, 2024
To: Katie Hentrich, CAP Administrator
Dear Katie,
On behalf of the Sierra Club’s Coaster group, I’d like to share some insights with the Climate Action Plan (CAP)
update you prepared. Our local Carlsbad Sierra Club team has had a chance to review and discuss the measures
presented within this current update.
This update is a vast improvement over the original 2015 CAP. It is much more readable and comprehensive
than the original. Staff has done an excellent job of covering just about all potential areas for reducing
greenhouse gas (GHG) emissions. We appreciate the effort put forward by Ms. Hentrich to engage our team in
her outreach to address our concerns.
Before addressing specific measures, we’d like to make some general comments:
• It’s unfortunate that the best GHG inventory for transportation we have is from 2016. Our city needs to
work with SANDAG to get more current data and have it done regularly on a bi-annual basis. With this
sector accounting for 50% of our emissions it’s critical that timely, reliable inventories are available to
make informed decisions.
• Factored into our targets are the contributions from state and federal actions to lower our GHG
emissions. For 2035 those combined actions account for 53% of our emissions, for 2045, 72%
(calculated from Table 2-3, page 2-8). Very few agencies are meeting their targets in a timely manner
and, therefore, the city should be aggressive in its goals to account for greater future costs and potential
shortcomings by the state and national governments.
• While outreach to specific groups, including us, has been helpful, the general public knows little about
the climate crisis and what the city is doing to mitigate it. Community workshops would be helpful to
educate the public and encourage them to take positive actions in their own lives. Make “How you can
help” a prominent link to the higher order Environmental Sustainability webpage with includes the CAP.
• Somewhere within the CAP the city should set a target date for zero carbon that is at least as aggressive
as the state of 2045.
• The city should expand its commuter mode shift goals citywide with targets to meet or exceed 50
percent walk/bike/roll/transit by 2035.
Energy measures:
E-1 – For municipal facilities consider opting up to 100% renewable energy with the Clean Energy Alliance (CEA)
sooner than later. Also, replace, at end-of-life gas appliances with electric as much as possible.
E-2 – The target date for CEA to supply all its customers with 100% renewable energy is 2035. As with the
amendment to the first CAP, clean energy through CEA is one of the best ways of meeting our emission targets so
consider a target for the city to have its default program for our residents be Green Impact (=100% clean energy)
by 2030.
Oct. 2, 2024 Item #1 133 of 157
Explore, Enjoy &
Protect the Planet
E-3.2 (non-residential) and E-4.2 (residential) – For new construction, now that the Berkeley case has been
finalized, proceed with reach codes that apply high-performance, electric-preferred buildings. Encinitas is
finalizing their ordinance and San Luis Obispo passed theirs last fall. Such ordinances look to optimize energy
efficiency while still allowing for gas. Because the life span for new buildings is decades, Carlsbad should update
its building codes now to get the most emissions savings by encouraging electrification.
E-5 – The Building Energy Benchmarking program is being taken over from the state. We need to ensure that the
energy consumption reporting is accurate and timely and shared with building owners to help them make
decisions about becoming more energy efficient.
E-6 – Decarbonizing existing buildings will be a challenge. Therefore, aside from a target for 100% clean
electricity, steps need to be taken to reduce or eliminate gas use in our current building stock. This means
encouraging moving away from gas appliances AT LEAST at the end of their life span, if not sooner. As mentioned
earlier, most residents don’t know much about climate actions including alternatives to gas water heaters, HVAC
and cooking. Education and outreach are critical for this. The city should consider incentives to promote and
track electrification installs when pulling permits.
Transportation measures:
This sector, accounting for 50% of our GHG emissions, is the most intractable with our southern California love of
cars and independence. Bike lane and pedestrian improvements help and traffic calming measures promote
road safety and lower emissions. But getting folks out of there cars will be difficult without some incentives.
T-2 – The Transportation Demand Management (TDM) program for businesses was part of the original CAP and
didn’t have much of an impact because it only addressed new businesses. In addition, it had a somewhat high
threshold (average daily trips of >110 for employees) so only a few new businesses were mandated to have a
TDM plan. There is room to lower that threshold to include more businesses, as pointed out in the CAP update.
Also, existing businesses, particularly those large ones, should somehow be included in the program. Again, the
sooner the recruitment is increased the greater the impact on our GHG reductions. The public should get an
annual update on this program as part of the annual CAP reporting.
T-3 – While the Safe Routes to Schools doesn’t specifically cover idling, it should. Because Carlsbad Unified
School District has no school buses, the majority of our students drive themselves (high school) or have parents
drop off and pick them up. This latter group often encounters lines at the schools resulting in excess idling which
contributes to both GHG emissions and other air pollutants impacting student health. The city should be
working with our school districts to implement anti-idling at our school sites and/or promoting much higher
alternative modes of transport to and from schools.
T-7 – It’s good to see the TDM program being expanded to include city facilities/employees. The city should be a
role model for businesses in our region and this is a good way to do that.
T-8 – To increase the use of EVs the expansion of charging infrastructure is important. While the city updates its
EV Siting Plan, staff should look at the Public EV Charging Infrastructure Playbook if they haven’t already done so.
T-9 – Updating the city fleet to all electric vehicles should be the target. Last summer the majority of the council
voted to purchase 40 all gas-powered police cruisers rather than consider alternatives. Let’s hope this measure
does a better job at addressing the problem of transportation emissions even in public service vehicles than
we’ve seen recently. EVs will also have a payback in reduced maintenance costs as the fleet ages.
T-10 – Proper parking management can be a valuable tool to incentivize employees not to drive. It should be
included within the TDMs for both businesses and the city (T-2/T-7). As worded in the CAP update, this is a
Oct. 2, 2024 Item #1 134 of 157
rather vague measure and primarily addresses actions through existing plans like the Village and Barrio Parking
Plan rather than a city-wide business approach to reduce employee trips. Free parking is not free and the city
needs to look to the future in evaluating its parking strategies.
Off-Road Equipment Measure:
OR-1 – As written this measure only addresses gas-powered leaf blowers. As much as possible it should include
all lawn equipment. To prevent a financial hardship to landscapers, phase in this measure over 1-2 years, like
Encinitas did, to allow for end-of-life conversion to electric equipment.
Carbon Sequestration Measure:
CS-1 – Community Forest Management which includes a replacement of 2:1 for city trees should be expanded to
include HOAs which may have CC&Rs covering tree replacements. Oftentimes, our informal survey of some
HOAs in Oceanside found that tree replacement policies are not be followed. Hopefully, Measure CS-1.c, the 5-
year urban canopy study will include this.
In closing, we support all the measures present in the CAP update with our suggestions for improvements. The
most critical component is this: the sooner the measures are implemented the greater the GHG savings. Global
action isn’t happening fast enough. Every level of government should be doing their utmost to address the
problem. Carlsbad has the opportunity to lead by example.
Thank you for your consideration.
Paige DeCino
Paige DeCino
Coasters Executive Committee member
Oct. 2, 2024 Item #1 135 of 157
Oct. 2, 2024 Item #1 136 of 157
NORTH COUNTY
TRANSIT DISTRICT
Bl0MissionAvenue August 15, 2024
Oceanside, CA 92054
(760) 966-6500
(760) 967-2001 (fax)
GoNCTD.com Katie Hentrich
Climate Action Plan Administrator
City of Carlsbad
1635 Faraday Ave
Carlsbad, CA 92008
Sent Via Electronic Mail: katie .hentrich@carlsbadca.gov
Re : Carlsbad -Draft Climate Action Plan Update -July 2024
Dear Ms. Hentrich :
The North County Transit District (NCTD) appreciates the opportunity to provide
input on the City of Carlsbad's Draft Climate Action Plan (CAP) Update, based on
Notice of Draft Availability via Citywide email published on July 8, 2024. NCTD
commends the dedicated efforts of the City staff in updating the CAP. Additionally,
we recognize that the successful implementation of this plan will require ongoing
collaboration among various stakeholders, including City officials, community
members, and regional partners.
As a partner agency, NCTD plays a major role in the region's climate action efforts
through our comprehensive public transit services. Since 1975, NCTD has served
Northern San Diego County, reducing reliance on single-occupancy vehicles and
lowering greenhouse gas (GHG) emissions. In FY18, our transit system saved 46
million auto miles traveled and reduced GHG emissions by 14 ,000 short tons. By
2050, NCTD anticipates saving 123 million auto miles traveled and reducing GHG
emissions by 54,000 short tons (NCTD Public Benefits Study, 2021 ).
NCTD's recently adopted Sustainability and Climate Action Plan (SCAP) sets a
strategic framework for achieving carbon neutrality by 2050. This includes
transitioning to zero-emission vehicles, diversion of waste from landfill, and reducing
emissions from electricity consumption . Supported by a recent grant from the
California Department of Transportation (Caltrans), NCTD is also developing a
Climate Adaptation and Infrastructure Resiliency Plan. NCTD is committed to
collaborating with the City of Carlsbad and other stakeholders to enhance
sustainability and resilience in our transportation system , creating a cleaner future
for our region.
Oct. 2, 2024 Item #1 137 of 157
Re : Carlsbad -Draft Climate Action Plan Update -July 2024
August 15, 2024
Page 2 of 3
NCTD emphasizes that mode shifting to public transit, such as fixed-route bus and
rail, is vital for reducing vehicle miles traveled (VMT) and overall carbon emissions.
By prioritizing the expansion and improvement of public transit infrastructure, public
transportation options would be more accessible and attractive to residents . This
effort not only supports our environmental goals and promotes equity by ensuring
diverse and underserved communities benefit from reliable and affordable transit
solutions, but it also meets the requests of the public feedback captured and
presented in the CAP.
NCTD recommends the City include the following in the Final CAP:
• Measure T-5 : Pedestrian System Improvements
o Prioritize Americans with Disability Act (ADA) sidewalk installation and
improvements connecting to public transit services and bus stops. It
is essential as it enhances accessibility, making it safer for residents
to reach transit stops and to board our wheelchair accessible vehicles
(WAV). Improved pedestrian infrastructure encourages more people
to use public transit, thereby reducing reliance on single-occupancy
vehicles, decreasing traffic congestion, and lowering greenhouse gas
emissions.
o NCTD recommends adding the following sentence under Measure T-
5: "Equity Considerations:"
■ Prioritize sidewalk improvements around transit services and
stops to ensure safe and accessible pathways for all residents,
particularly for youth, and those from underserved, disabled,
low-income, or older adult communities.
• Measure T-6: Local Transportation Improvements
o Modify the language in Action T-6 .a: "Explore local transportation
improvements to provide sustainable on-demand, flexible fleet transit
and first-mile last mile solutions" to "Explore local transportation
improvements to provide sustainable on-demand, flexible fleet transit
and first-mile last mile solutions that complement existing fixed-
route bus and rail transit services."
■ This would reflect the sentiments of the community and
stakeholders, as gathered through the CAP Update outreach.
o Designate Action T-6 .d: "Coordinate with regional and local agencies
and partners on influencing transportation improvements throughout
the region and within Carlsbad", as a primary implementation action .
■ To this action, NCTD recommends adding the following
language: " ... such as supporting fixed-route frequency
increases, ensuring sidewalk infrastructure allows for ADA
boarding/alighting , improvement of bus stop amenities to
encourage ridership, and pursuing transit-supportive
infrastructure."
Oct. 2, 2024 Item #1 138 of 157
Re : Carlsbad -Draft Climate Action Plan Update -July 2024
August 15, 2024
Page 3 of 3
o NCTD recommends adding the following content under Measure T-
6.d: Equity Considerations":
■ ''Engage transit riders and community leaders from
underrepresented or disadvantaged groups to provide input on
transit projects."
■ "Ensure transit services are accessible to older adults and
individuals with disabilities."
Thank you again for allowing NCTD to review and comment on the City's CAP
Update. Should you have any questions, feel free to contact me at (760) 966-6683
or via e-mail at kpersons@nctd .org.
Sincerely,
Katie Persons
Director of Service Planning
cc: Chris Orlando, Chief of Planning, Marketing, & Communications, NCTD
Nick Sofoul , Director of Strategic Planning & Transit Systems, NCTD
Lillian Doherty, Director of Planning & Development, NCTD
loni Tcholakova, Senior Transit Planner, Service Planning , NCTD
Mary Balderrama, Senior Transit Planner, Service Planning , NCTD
From:Vanessa Forsythe
To:Katie Hentrich
Subject:Carlsbad CAP Update Support & Comments
Date:Friday, August 16, 2024 10:42:33 AM
Greetings Katie
I support overall the updates to the Carlsbad Climate Action Plan. It is much improved in
readability and indicating avaialable data and goals.In addition I believe these also need to be brought forward: #1 a REACH code that indicates
electric preferred to gas on new building construction, #2 incentives to replacing gasappliances with electric ( informing public existing rebate / tax incentives / longer term cost
savings) particularly for electric/ induction stoves, electric water heaters and HVAC heating/cooling systems; # ahead of state mandates prepare business and builders expected regulations
# inform public with forums / workshops by staff addressing the CAP measures, need toreduce GHG locally related to climate shift included in upcoming city's 5 year plan at
libraries, community centers and Carlsbad School District Office of Esucation; # haveCommunity Communications Board on line that addresses CAP impacts including measures
as where to where we are through EPIC ( as we get out in years realizing it will be harder tomeet goals - need to do more in short term)# doing well in parks except for south west but
also need more trees ( always ) removal of invasive plants at parks and lagoons with plantingof more native plants and natural ( grass) turf # no to synthetic turf ( releases VOCs and is
plastic that ends up being incinerate more toxins in air) # put solar over all parking lots andmunicipal structures # post how much tonnage ( going to landfills) reduced by doing
community food / green waste collection, # incentives with recognition businesses beingelectric and reducingTDM outside of working from home; # set 100% renewable through
default CEA by 2030 , work with school district for posting of no idling signs ( doesn't requirepolice enforcement). Lastly I concur with the recommendations presented in Paige DeCino's
August 12 letter as member of Coastals Committee.Thank you
Vanessa Vanessa Forsythe RN MSN
She/Her
California Nurses for
Environmental Health & JusticeLeadership Council
https://climatehealthnow.org/Clean Earth 4 Kids
Board Memberhttps://cleanearth4kids.org/
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Oct. 2, 2024 Item #1 139 of 157
From:Colleen Blackmore
To:Katie Hentrich
Cc:Jeff Murphy; Paul Klukas; Colleen Blackmore
Subject:RE: Reminder - Draft Climate Action Plan Update available
Date:Friday, August 16, 2024 11:48:00 AM
Attachments:CRC Summary of CAP Issues Tenant Imp.doc
Hi Katie,
We have reviewed the Draft CAP Update document and are surprised to discover that there is no
mention of the Carlsbad Research Center’s Board of Director’s (CRC BOD) input and comments
regarding the increased costs to CRC business and property owners that these policies produce.
TI thresholds in the document are still dollars-based $200,000 and $1 million, even though the
CRC finds that there is no direct relationship between cost of TI improvements and pollutant
emissions, and that the CRC is already observing that routine building improvements and
updates in Carlsbad’s premier business park are being curtailed as the result of the penalizing
costs associated with the added solar and transportation-demand improvements.
We see no mention of the CRC BOD’s recommendation to use “change in intensity of use” or
“percentage of floor area increase” as thresholds for the CAP-required improvements, rather
than assessed value. There is no mention of the economic costs to business, which is
ultimately borne by the community in the form of higher costs of products and services.
We also expected that our memo sheet provided to City Staff (copy attached), which included
a few recommendations, would at least be included in the Appendix. Please let us know why
our input was not considered in your Draft CAP Update.
Thank you.
Colleen M. Reilly
President
Carlsbad Research Center Owners’ Association
THE BLACKMORE COMPANY
1811 Aston Avenue
Suite 102
Carlsbad, CA 92008
760.804.9600
From: Katie Hentrich <Katie.Hentrich@carlsbadca.gov>
Sent: Monday, August 12, 2024 9:08 AM
To: Katie Hentrich <Katie.Hentrich@carlsbadca.gov>
Subject: Reminder - Draft Climate Action Plan Update available
Oct. 2, 2024 Item #1 140 of 157
Good morning,
I wanted to send a reminder about providing feedback on the public draft of the city’s Climate
Action Plan Update.
A Planning Commission workshop will be held on September 4, 2024. Thisworkshop is open to the public. This will be an informational item only; thePlanning Commission will not be making a recommendation to the City Council.Staff will then present the Draft Climate Action Plan Update to the Planning Commissionat the October 2, 2024 meeting.Staff anticipate a presentation to the City Council later in the fall.
If you are interested in providing input, you can:
Review the executive summary here (English / español)Review the public draft hereSubmit a comment to staff to be included in the Planning Commission workshopmaterialsPlease send comments to katie.hentrich@carlsbadca.gov by Friday, August16Comment in writing or in person to the Planning Commission for the September 4workshop
I’d like to also offer my time to go over any questions or comments you may have. If you’d liketo meet or have a larger group you would like me to share this information with, please let meknow and we can set something up.
All comments submitted for the Planning Commission workshop will be included in the
upcoming Planning Commission and City Council staff reports. Following the Planning
Commission workshop, we will send more information on how to participate at the other
upcoming meetings.
If you have already submitted a comment or scheduled a meeting with me, please ignore thismessage and thank you very much for your time.Please do not hesitate to reach out if there are any questions. Do you need an interpreter orany other assistance in order to participate? Please call me at 442-339-2623. ¿Necesitasun intérprete o cualquier otra asistencia para participar? Comunícate al 442-339-2623.Thank you very much for your consideration and participation,
Katie Hentrich
she | her | hers
Climate Action Plan Administrator
Environmental Sustainability
City of Carlsbad
1635 Faraday Ave.
Carlsbad, CA 92008
www.carlsbadca.gov
442-339-2623 | katie.hentrich@carlsbadca.gov
Oct. 2, 2024 Item #1 141 of 157
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Oct. 2, 2024 Item #1 142 of 157
CAP DISCUSSION ITEMS – TENANT IMPROVEMENTS
Subject. Carlsbad Research Center R&D/Office Building Tenant Improvements (TI’s)
Problematic City of Carlsbad CAP Requirements. The new City of Carlsbad CAP requirements state that all TI projects in existing buildings must comply with the following;
(a) TI projects valued at over $200,000 or adding 1,000 sf or more in floor area must addressconsistency with the Energy Efficiency and Transportation Demand Management factorsidentified in the CAP Checklist; and,
(b) TI projects over $1 million valuation must also address increased Energy Efficiencyfactors, and increased Transportation Demand Management considerations.
Our experience on how the above CAP requirements negatively affect the CRC tenant improvements fall into two main categories, as follows:
ISSUE #1: Using the Cost of TI Improvements as a Threshold is Unrelated to Reduced GHG’s. The
threshold valuation limits adopted by the City are so low that even very minor TI’s, where no substantive change in use or intensity of the floor area is proposed, trigger additional costly energy efficiency and complex transportation demand analysis and improvements. In the CRC, it
is not unusual for a simple tenant change to result in over $200,000 or over $1 million valuation of TI’s. This is particularly true in today’s inflationary financing and construction climate.
Recommendation. An improved approach could be considered, such as “change in use” or “percentage of floor area increase”. In our experience, these factors (whether enforced through substantive policy refinements or as interpretive guidelines) more directly result in a tenant’s ultimate contribution to energy demand and commuter GHG emissions. Using a percentage, rather than a minimal finite limitation, would allow relatively minor TI’s that simply re-arrange [or reduce the intensity] of the same uses to be undertaken without enduring the costly CAP improvements.
ISSUE #2: The Existing Thresholds Discourage Improvements . As mentioned, virtually all TI’s in existing buildings in the CRC are appraised in excess of the $200,000 limit. TI’s costing this amount
require installation of solar panels and transportation demand requirements and improvements. The cost of the added expense of the solar and transportation improvements frequently discourages the improvements, as they make the TI’s cost prohibitive. Further, many building
owners request TI’s in order to upgrade a vacant floor area in advance leasing, in the hopes that the improvements will upgrade the building and attract a high-quality tenant. Accepting costly solar panel requirements or preparing a TDM plan without specific knowledge of the tenant or their operating procedures is largely imprecise guesswork, and most likely to be inaccurate. Reconfiguration of floor area does not automatically denote increased CAP emissions. So, this lack of accurate assumptions in the CAP analyses and resulting conditions; (a) are likely to be erroneous, (b) engender resistance from potential tenants, and (c) put Carlsbad at a disadvantage in the R&D and office leasing market.
Oct. 2, 2024 Item #1 143 of 157
Recommendation. An improved approach could be considered for these generic TI’s that improve Carlsbad’s look and business climate. This approach could involve deferring identification of the specific CAP-required improvements until some later point in the business-authorizing process, such as a condition of business license issuance. This will allow the required analysis of the business to be conducted by the entities who are most knowledgeable of the business operations. Premature analysis of business operations and resulting GHG emissions results in confusion, and distorted requirements.
ISSUE #3 Energy producing equipment on existing buildings is too expensive. Solar or alternative energy producing equipment is too costly to achieve on existing buildings. The updated building codes
already require increased energy efficiency (energy efficient HVAC units, LED lighting, Title 24 controls, reduced water flow plumbing fixtures, etc.). Solar panels or other alternative energy facilities necessitate expensive structural and mechanical retrofits of existing buildings, making
routine TI improvements cost prohibitive.
Recommendation. TI compliance with the updated building codes should be considered
satisfactory mitigation for energy efficiency with regard to CAP compliance.
ISSUE #4 Insignificant increases of “demand” should not trigger CAP upgrades. It does not seem equitable to require costly improvements when no relationship exists between the projected emissions “demand” resulting from the proposed TI’s and the CAP requirements.
Recommendation. TI’s that result in minimal or less intensity of CAP emissions should be considered exempt from the CAP requirements. The removal of existing TI improvements should be credited against any corresponding increase in intensity for purposes of analyzing and applying CAP upgrades. Thus, if the net balance of emission generation (increase of x number/size vs. removal of x number/size) is positive, the CAP requirements would be prescribed. If the net balance between increase vs. decrease is even or negative, no CAP improvements should be required.
Oct. 2, 2024 Item #1 144 of 157
From:Zachary Zeilman
To:Katie Hentrich
Cc:Mitch Silverstein; Jasmine Mikesell
Subject:Comments for Carlsbad Climate Action Plan Update
Date:Friday, August 16, 2024 1:39:47 PM
Hi Katie,
Thank you and Aidan for meeting with us a few weeks ago to discuss the Carlsbad CAP andother related climate items.
Please see below for comments from Surfrider San Diego Chapter that we would likeconsidered in the update. Apologies that the formatting is a little off.
1.
Water
1.
Decrease ornamental turf beyond state law requirements and incentivize native
and/or drought tolerant lawns through a “xeriscaping” requirement
2.
Energy
1.
Develop a reach code for electrification with different standards for residential
and commercial, recognizing that residential contributes an outsized share of
GHG but that financial burden may be excessive on households, particularly
lower and middle-income
2.
Conduct a study for implementing solar-covered carports or increase solar in
other ways on City-owned properties or partner with/incentivize private
landowners where appropriate
3.
Conduct outreach and pilot programs to decarbonize existing buildings
voluntarily
i.
Apply square footage to existing reach codes
ii.
Develop an incentive program such as appliance trade-outs
3.
Oct. 2, 2024 Item #1 145 of 157
Solid Waste
1.
Create a fee structure based on how much waste households dispose of based
on volume or weight (Consider examples from other cities, such as proposed
updates to the City of San Diego People’s Ordinance or Dresden, Germany)
2.
Mandate and measure organic recycling diverted from landfills. Develop a
program to provide organics compost to farms for soil or consider plans to send
to or construct an anaerobic digestion facility
4.
Transportation
1.
Develop a percentage goal for VMT reduction that harmonizes with the 2022
CARB Scoping Plan which calls for a 25% reduction
2.
Fund electric schools buses (or any school buses) to reduce emissions and
VMT for individual households dropping kids at school, while also being more
equitable
3.
Implement a bike sharing program that could be regional between Oceanside
and Encinitas to immediately help first/last-mile difficulties
4.
Parking Management Strategies
i.
Eliminate or reduce parking minimums for development
ii.
Shared or unbundled parking for new developments, commercial &
residential
iii.
Quantify the Parking Management Plan (2017) adopted for downtown
area and approve by-right
5.
Adopt and implement a Safe Routes to School Plan that incorporates safe
walking and biking infrastructure between neighborhoods, schools, and other
Oct. 2, 2024 Item #1 146 of 157
public facilities
5. Other Community Forestry Plan - Look into feasibility of native plant ordinance too that are
drought tolerant. Remove palms and eucalyptus from preferred trees.
Thanks again!
Zack
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Oct. 2, 2024 Item #1 147 of 157
August 16, 204
Mayor Blackburn and Council,
City of Carlsbad
1635 Faraday Ave, Carlsbad, CA 92008
Via Email
Re: Climate Action Campaign recommendations for Carlsbad’s Climate Action Plan
Update
Dear Mayor Blackburn and Council,
Climate Action Campaign (CAC) is a San Diego based nonprofit organization with a simple
mission: create a zero carbon future through effective and equitable policy action. We have
played an active role in the development of Climate Action Plan’s (CAP) throughout the region
since 2015.
Climate Action Plan Administrator Katie Hentrich reached out to us to ask that we provide
comments on your draft CAP. Here are our comments and recommendations:
What we Applaud in the CAP Update:
●Ensuring the City reaches 100% clean energy is crucial for reducing emissions and
ensuring a just, climate-safe future. The draft CAP update has strong goals in Measure
E-2 to set 100% renewable electricity as the default option for Clean Energy Alliance
customers in the City. This is a critical step towards the clean energy future we need and
are pleased to see Carlsbad incorporating this as a priority in the CAP.
Upgrade Clean Energy Measures
With natural gas being responsible for 14% of Carlsbad’s greenhouse gas (GHG) emissions,
electrifying new and existing buildings are essential actions for reducing pollution and improving
air quality.
●Measures E-3 and E-4: Measures E-3 and E-4 address methane gas in new
construction and identify ways to update existing reach codes to further reduce the
impacts of gas in residential and nonresidential buildings, though stronger and more
detailed timelines for implementation are needed. Once the new state building code is
Oct. 2, 2024 Item #1 148 of 157
CAMPAIGN
SAN DIEGO/ ORANGE COUNTY/ LOS ANGELES
adopted next year, Carlsbad can choose the voluntary option to ensure new buildings
are safe, healthy, and climate resilient.
●Measure E-5:The current draft CAP update includes an important foundational step to
modernize and make existing buildings safe and energy-efficient in Building Energy
Benchmarking in Measure E-5, but benchmarking only supports critical
information-gathering and analysis. The CAP update is missing a Building Performance
Standard which is necessary to regulate pollution from existing buildings. Without a
standard, Carlsbad will not be protecting their residents from dangerous exposure to
fossil fuel pollution.
●Add this Missing Measure:A measure should be established for developing and
implementing a Building Performance Standard and should include scope, scale,
estimated costs, specific planning and implementation timelines, and an outline for
community and stakeholder engagement. It is also essential that equitable electrification
for Communities of Concern and new job opportunities for fossil fuel workers be key
elements in all building electrification strategies.
Upgrading Transportation Measures
The CAP’s cumulative measures to address GHG emissions from transportation are woefully
insufficient. By the City’s own projections, transportation emissions will still be the highest sector
for GHGs by 2045.
On August 23, 2023, the City of Carlsbad declared a local state of emergency regarding a 233%
increase in collisions involving bikes and ebikes between 2019 and August 2022. As the use of
e-bikes increases it necessitates the adoption of safe transportation infrastructure to help
facilitate safe streets for everyone, especially near and around schools.
●Measure T-3:We commend the City of Carlsbad on their initiative to address Safe
Routes to Schools to help promote safe walking and biking. However, the emphasis
needs to be on engineering and redesigning streets with safe infrastructure since
education and enforcement are not elements that address the lack of safety in the built
environment where streets are built for high speed and cut through traffic.
●Measure T-1, T-3 and T-5: The CAP’s Safe Routes to School is missing important
pedestrian safety components for safe crossing such as speed tables and flashing
beacons for mid-block crossings. Sidewalks are not enough because at some point folks
need to cross fast and dangerous streets.
●Measure T-4: Paint is not enough. The City of Carlsbad needs to take a Class IV
approach where biking is secure, safe and separated from fast, free flowing traffic. We
commend the City on their plans for Class I bike lanes, but the need for a network of
safe and protected bike lanes requires a Class IV approach in addition to multiuse bike
trails.
Oct. 2, 2024 Item #1 149 of 157
●Measure T-3, T-6 and T9: The reduction of speed is a missing tool in the CAP. Utilizing
AB 43 to slow streets will be essential to ensuring Safe Routes to School. AB 43 is also
a powerful tool to create a network of streets that are 35 MPH or less for NEV/LSV for
residents, staff and tourists alike. Carlsbad is the perfect city for street-legal golf carts
and neighborhood electric vehicles. In fact, the City’s fleet conversion to all electric can
include NEVs.
Centering Equity and Green Jobs
Overall, equity has been thoughtfully and clearly integrated throughout the CAP update. We
acknowledge and appreciate the effort Carlsbad has made with reaching out to communities,
especially tribes, as well as the efforts put into engaging communities through workshops,
listening sessions, and events. Here are some recommendations for improvements.
●The City of Carlsbad needs to prioritize Communities of Concern, who are first and
foremost impacted by the climate crisis, by identifying funding to create tools such as the
Climate Equity Index that cities like Chula Vista and San Diego have.
●The City of Carlsbad should partner with universities, schools, and labor unions to
ensure access to apprenticeship programs and other pipelines for high-paying jobs
within renewable energy or circular economy sectors.
●Finally, we encourage the City of Carlsbad to consider community residents who may not
be residents due to lack of affordability, but are still vital members of the community as
workers or are tribal members who have been displaced from their ancestral coastal
homelands.
○Examples include ensuring that workers have access to rebates or home-owner
purchased electric leaf blowers (to account for bans on gas-powered leaf
blowers) as well as access to affordable and accessible renewable energy-based
transportation options. This access should include education about alternatives to
gas-powered appliances, as well as potential travel vouchers or rebates for
electric vehicles or bicycles.
○Other examples include working with tribes to ensure renewable energy-based
transportation from the reservations to the coast through electric shuttles or
vouchers for public transportation options.
Thank you for the opportunity to weigh in on the development of this critically important
document.
Sincerely,
Anthony Dang
Policy and Community Outreach Manager
Climate Action Campaign
Oct. 2, 2024 Item #1 150 of 157
NAIOP San Diego
BOMA San Diego
San Diego Regional Chamber of Commerce
California Apartment Associa=on
Southern California Rental Housing Associa=on
California Restaurant Associa=on
Building Industry Associa=on of San Diego
San Diego County Lodging Associa=on
Associated General Contractors San Diego
TRANSMITTED ELECTRONICALLY
August 16, 2024
Ka/e Hentrich, CAP Administrator
Environmental Sustainability
City of Carlsbad
1635 Faraday Ave.
Carlsbad, CA 92008
RE: DRAFT Climate Ac/on Plan Update Comments
Dear Ka/e:
On behalf of the undersigned coali/on, please accept our comments on the draP Climate Ac/on
Plan (CAP) Update documents the City has posted on its website. As previously communicated,
much of the draP iden/fies goals and thema/c requirements, but does not provide sufficient
detail to determine what would actually be required of Carlsbad property owners.
Unfortunately, numerous jurisdic/ons have taken the same approach, which seems by design,
to build momentum for yet to be iden/fied implementa/on measures that could be costly and
unachievable. Our coali/on has strong concerns about this approach because this masks the
true costs and actual implementa/on challenges, and obfuscates for the public what might be
required of them to achieve these new standards.
Targets WILL be met WITHOUT the need to adopt more stringent requirements
Oct. 2, 2024 Item #1 151 of 157
It should also be noted that the city’s own analysis shows that you are going to achieve the state
required targets by 2035. The measures to achieve this are already extremely onerous, and
going beyond them will have significant impacts to the city’s ability to create housing and jobs.
Longer term goals are so far out that it would be prudent to hold off on new and more onerous
mandates on private property owners, par/cularly in these uncertain economic /mes.
State requirements are only geHng STRONGER
Given the stated desire to address longer term target “trajectories,” it’s important to consider
that the State of California, both through the legisla/ve process, as well as the regulatory
process, through its triennial building code updates, is constantly ratche/ng up its energy
conserva/on and GHG reduc/on requirements. This applies to both the built environment,
through Title 24, among others, as well as in transporta/on for both commercial and personal
vehicles. In fact, the State of California will soon be releasing its new statewide building code
before the end of the year, which promises an even more stringent set of energy conserva/on
and GHG reduc/on requirements. The City should wait un/l these new rules are published and
then analyze their beneficial impacts on further reducing GHG emissions to determine what, if
any, delta to the targets would exist.
Transporta=on is the MAIN driver of GHG, not the built environment
As the greenhouse gas inventory conducted by city staff demonstrates, the vast majority of
climate emissions are from transporta/on. This is an area where the state is making big strides,
par/cularly with recent mandates to phase out sales of gas combus/on consumer and business
vehicles. On the local level, our coali/on believes the best way to control transporta/on
emissions is to increase job crea/on adjacent to where people live. In Carlsbad, while there has
been excellent planning to try and balance jobs and housing, more could be done on this front
to improve the distance between where people live, where they work and where they seek
their services. Adding new and onerous burdens to construc/on will only work against this kind
of meaningful co-loca/on that balances jobs-housing-services.
Carlsbad property owners and jobs creators are PARTNERS in the effort
The ability to achieve these ever increasing and stringent goals are an indica/on of the strong
partnership with the business community and your residents. Our coali/on has invested
millions of dollars in upgrading for energy efficiency, and building new structures that are some
of the “greenest” on the planet. Rather than pursuing aspira/onal and economically
debilita/ng “REACH” codes, the City should instead look at incen/ves to help further promote
GHG reducing ac/ons by the private sector. The City should celebrate the greenest
developments.
INCENTIVES work when seeking more than what is already required
Oct. 2, 2024 Item #1 152 of 157
An excellent example is in the installa/on of photovoltaic as well as the acquisi/on of electric
vehicles and installa/on of EV chargers. When incen/ves, like tax credits, are applied,
acceptance and adop/on increase exponen/ally. When they stop or are reduced, like the
recent decision by the CPUC to change net metering rules, adop/on drama/cally drops. The
City should focus on incen/ves for change, rather than mandates which only harm small
businesses and divert limited investment capital.
Costs to the private sector were never fully analyzed
The City did a good job of analyzing the impact of the proposed CAP requirements to itself. This
included an analysis of the cost to the city of improving all city buildings and the vehicle fleet,
as well as the cost of city staff /me to implement and regulate the CAP. Unfortunately, the city
did not similarly detail the impact to the private par/es who are subject to these poten/al new
and significant requirements. We would respecf ully ask that staff be directed to do a
meaningful cost impact analysis and one that takes into considera/on the investment cycle for
businesses. We have seen, when these kinds of analysis are done, the consultants oPen refer
back to extremely long /meframes for amor/za/on of the cost, similar to a mortgage type
ownership length. Businesses assess investments in capital improvements over a much shorter
period of /me, usually about 5 years. Despite the comments in the staff report that these
improvements “save money”, the poten/al requirements are expensive investments that will
lead to higher costs for goods, services and housing in the near and mid-term. These costs
should not be given short shriP.
The City should take ac=on to LEAD in the mean=me
In addi/on to incen/ves, the City should take ac/on to address its own greenhouse gas
emissions. Leading by example and inves/ng in its own efforts, as detailed in the staff report,
would be a signaling message and provide addi/onal reduc/ons not contemplated under the
city’s currently approved plan. Those ac/ons include:
•Wastewater energy efficiency improvements •Water recycling expansion and energy efficiency improvements •Renewable energy expansion at city facili/es, including solar carports at city facili/es •Energy efficiency improvements at city facili/es •Expansion of clean vehicle fleets for city vehicles
Addi=onal comments
With these general thoughts in mind, we offer the following comments on the theme areas
included in the draP plan:
•Energy efficiency in non-residen=al and residen=al buildings - as stated above, any
addi/onal requirements should be delayed un/l the requirements of the new state
Oct. 2, 2024 Item #1 153 of 157
building code can be reviewed. REACH codes cost money, which results in higher rents
and, in many cases, a movement of investment outside the city. Statements that these
improvements “save money” are overstated and incorrect. This is basically a new tax on
jobs creators, small businesses and city residents. In the interim, the city should find
incen/ves to spur energy efficiency improvements in exis/ng buildings.
•Energy performance requirements for both non-residen=al and residen=al buildings -
this is electrifica/on by another name. Our coali/on would like to point out that a lawsuit
brought against the City of Berkeley successfully blocked the manda/ng of building
electrifica/on. Sei ng performance standards that can only be met through electrifica/on
would essen/ally create the same mandate. Staff has noted that there may be other ways
to achieve the performance standards, but it’s unclear how the performance standards
would be applied to different types of buildings, and, as such, the total reduc/on sought
could end up crea/ng de facto requirements that would be economically prohibi/ve,
impac/ng your businesses and your homeowners. This should not be adopted.
•Emissions benchmarking reports - state law already requires this repor/ng. Our coali/on
feels this is duplica/ve and unnecessary. That said, other jurisdic/ons, like the City of San
Diego, also have overlapping requirements for these reports. We would strongly
recommend, like how the City of San Diego addressed this same concern, that the required
reports mirror those already provided to the state. Energy Star Porf olio Manager is the
tool used, and we’d recommend that tool be used here, if a duplica/ve requirement is
adopted.
•Decarboniza=on of exis=ng buildings - it’s unclear what this means, but like the comments
on energy performance requirements, if the net result of this are new requirements to ban
natural gas, then there are legal concerns to consider. If there are other requirements
being contemplated, these will likely significantly increase costs. As noted previously, the
City will more than meet its goals in the next ten years. The City, rather than crea/ng new
legal risk, or raising the cost for City residents and employers, should look at incen/ves,
not new mandates.
•Waste diversion - the diversion of organic waste, while laudable, creates the poten/al for
unintended consequences. Any program should be phased in, and, most importantly, be
considered against other City requirements that might prevent implementa/on. An
example would be parking requirements. Most proper/es do not have the space to place
addi/onal dumpsters for newly diverted waste, crea/ng a compliance issues if parking
were to be taken up to place those receptacles.
•Transporta=on Demand Management - Transporta/on demand management is a
cau/onary tale. In some cases, mandates under a TDM program that drive either
opera/onal changes or impact employees from a cost or convenience standpoint could
drive businesses out of Carlsbad, which harms your economic development efforts, as well
Oct. 2, 2024 Item #1 154 of 157
as conflicts with the greatest means of reducing emissions, which is having jobs adjacent to
homes in your community. Voluntary programs, coupled with financial incen/ves to pay
for ride sharing are something to be used and expanded. Addi/onal analysis should also
be completed to determine the opportuni/es and impacts. Given COVID-era driven
changes in work habits, a number of employers are allowing an even greater share of work
from home opportuni/es, which may mean that these goals are already being readily met.
Focus should also be paid to improving the area’s transit services, including shuk le services
to and from rail sta/ons. Convenience drives behavior, so that could assist greatly in
reducing auto trips. Lastly, the State of California has already mandated the phasing out of
combus/on vehicle sales. There should be much less concern about vehicle emissions,
given the /me horizons for these mandates.
•Transporta=on - the City should focus on ways it can improve its circula/on network and
expand transit service rather than mandate expensive new requirements on jobs creators.
If electric vehicle requirements from the state, including the phasing out of combus/on
vehicle sales in the near term, are not enough, then the focus should be to work with
NCTD and AMTRAK to create bek er transit service to be an effec/ve and desirable
alterna/ve.
•EV charging and photovoltaic mandates should be carefully considered - these are
extremely expensive requirements that are not easily achieved, par/cularly in commercial
sei ngs, and not always effec/ve when usage is factored in. Serving those addi/onal loads
on a property-by-property basis can be challenging, and expensive. In most instances
where they have been installed, chargers sit vacant and unused. In others, they are targets
for theP and vandalism. The other considera/on is the ability of the u/lity to serve this
increased load, and on a property by property basis, the ability of the equipment providing
electrical service to also serve the on-site load. When it can’t, the cost to install new
equipment to serve the expansion of EV charging will be significant. As in other
comments, these mandates add to the cost of doing business or the cost of housing, and
our coali/on believes the cost-benefit should be a factor in these decisions.
•Parking Demand Management - Village and Barrio parking management studies are being
conducted, so no ac/on should be taken un/l those are done. Again, similar to the TDM
discussion, cau/on should be used in crea/ng rules or requirements that make it difficult
to develop or maintain a business within your community. Many of the ideas discussed
under TDM in this lek er could be considered for this as well. We do support the reduc/on
of parking standards in areas where alterna/ve means of transporta/on are readily
accessible.
•Construc=on vehicles - mandates of this nature, where the equipment is either not
available or extremely costly will only create compliance issues and place housing and jobs
space creators in an untenable posi/on. Even if the equipment were available, it is
expensive and results in higher costs of construc/on, which means more costly housing
Oct. 2, 2024 Item #1 155 of 157
and commercial space, neither of which should be acceptable, par/cularly given the
current economic environment. The City should instead focus on leading by example and
focusing its efforts on its own fleets and ac/vi/es.
In closing, we’d like to thank staff for hearing our call last year for bek er outreach. We have had
the opportunity to meet with your team and discuss the draP plan. We are hopeful that these
important concerns are taken seriously, and that the partnership the City prides itself on with
the business and property-owning community is honored.
Thank you for your /me and considera/on of these thoughts. Our organiza/ons are willing to
con/nue to discuss these issues as you proceed with more specific update proposals.
Sincerely,
Craig Benedek o, NAIOP San Diego & BOMA San Diego
Jus/ne Murray, San Diego Regional Chamber of Commerce
Melanie Woods, California Apartment Associa/on
Molly Kirkland, Southern California Rental Housing Associa/on
Chris Duggan, California Restaurant Associa/on
Lori Holt Pfeiler, Building Industry Associa/on of San Diego
Fred Tayco, San Diego County Lodging Associa/on
Dus/n Steiner, Associated General Contractors San Diego
CC: Paz Gomez, Deputy City Manager
James Wood, Director, Environmental Sustainability
Carlsbad City Councilmembers
Oct. 2, 2024 Item #1 156 of 157
From:Bob Wilcox
To:Katie Hentrich; Planning
Subject:Comment on draft CAP for Planning Commission
Date:Tuesday, September 10, 2024 10:30:35 AM
Members of the Carlsbad Planning Commission,
I encourage you to endorse the draft Climate Action Plan prepared by city staff, without
watering down, delaying or eliminating initiatives. As a Carlsbad homeowner and father oftwo (1 and 3 years old), I am encouraged that Carlsbad has such a thorough plan to reduce a
large portion of its carbon emissions through many different avenues in the future.
One area that I think could use more attention is further upzoning and approving more housingin our dense commercial districts like the Village, as well as along transit corridors and near
the Poinsettia train station. This is something that might be best addressed through theHousing Element of the General Plan, but these zoning changes would likely have a larger
impact on our region's long-term transportation emissions than many of the other proposed(and worthwhile!) initiatives. I understand that there are political challenges with such
changes, but the potential benefits are too great to ignore.
I want to express my thanks to the staff for all of their hard work on this comprehensive plan.
Regards,Bob Wilcox
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Oct. 2, 2024 Item #1 157 of 157
From:Planning
To:Eric Lardy
Cc:Cynthia Vigeland
Subject:FW: Query about strategy for the Carlsbad Planning Commission
Date:Monday, September 30, 2024 7:13:00 AM
From: evan wise <wiseinaz@gmail.com>
Sent: Saturday, September 28, 2024 1:38 PM
To: Planning <planning@carlsbadca.gov>
Subject: Query about strategy for the Carlsbad Planning Commission
With 27% of emissions coming from electricity, there should be a much greater
emphasis in the plan to reduce that to zero emissions to generate electricity. Strong
statements are needed concerning:
1. Nuclear power to generate electricity. Small Nuclear devices can replace the fossil
fueled fire box in coal plants to generate steam The turbine generators and grid ties
already exist.
2. Reduce the permitting process so that upgrades to the grid can be made to tie in new
alternative energy sources and deliver more power to the city as needed.
3. Modify the electrical pricing system. A few ideas include:
a. demand pricing each minute to level demand and reduce losses from changing
generation sources. Smart homes would be incentivized to drop non critical uses to take
advantage of the best pricing.
b. Incent EV owners to tie into the grid to supply backup battery power that can be used
to level demand.
c.Provide reduced pricing for all electric homes and buildings.
d. implement tiered pricing so that the more electricity a home uses, the higher the cost
of the incremental power delivered.
Electricity should be a clean and affordable source of power. Currently it is neither!
--
Evan Wise
wiseinaz@gmail.com
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From:Planning
To:Eric Lardy
Cc:Cynthia Vigeland
Subject:FW: Final CBAD PC Hearing Coalition Ltr - Oct 1, 2024
Date:Tuesday, October 1, 2024 12:41:08 PM
Attachments:Final CBAD PC Hearing Coalition Ltr - Oct 1, 2024.pdf
From: Craig Benedetto <craigb@calstrat.com>
Sent: Tuesday, October 1, 2024 12:10 PM
To: Planning <planning@carlsbadca.gov>
Cc: Erik Bruvold <ebruvold@sdnedc.org>; Lori Pfeiler <Lori@biasandiego.org>; Chris Cate
<chris@chrisjcate.com>; Molly Kirkland <mkirkland@socalrha.org>; Melanie Woods
<mwoods@caanet.org>; Melanie Cohn <mcohn@biocom.org>; Dustin Steiner
<dsteiner@agcsd.org>; Justine Murray <jmurray@sdchamber.org>; Lauren Cazares
<lcazares@sdchamber.org>; Fred Tayco <fred@lodgingsd.com>; Marshall Anderson
<marshall@calstrat.com>; Chris Duggan <cduggan@calrest.org>
Subject: Final CBAD PC Hearing Coalition Ltr - Oct 1, 2024
Dear Carlsbad Planning Commission Members. Attached is a letter from a coalition of jobs
creators and housing providers who represent numerous constituents in the City of Carlsbad.
Our members are deeply concerned about the impacts of some of the proposed measures in
the draft climate action plan update. We do believe these can be balance by moving forward
with the recommendations contained within our letter. These include support for the staff
listed recommendations 1 and 2, with some modifications to recommendation 2. We look
forward to the hearing tomorrow to discuss further. Thank you for your consideration.
Sent by:
Craig Benedetto
California Strategies
530 B Street, Suite 920
San Diego, CA 92101
O: (619) 546-7451
C: (619) 980-8032
E: craigb@calstrat.com
www.calstrat.com
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know the content is safe.
Biocom California
BOMA San Diego
Building Industry Associa:on of San Diego
San Diego Regional Chamber of Commerce
California Apartment Associa:on
San Diego County Lodging Associa:on
San Diego North Economic Development Council
Southern California Rental Housing Associa:on
California Restaurant Associa:on
Associated General Contractors San Diego
NAIOP San Diego
TRANSMITTED ELECTRONICALLY
October 1, 2024
Planning Commission
City of Carlsbad
1635 Faraday Avenue
Carlsbad, CA 92008
RE: DraG Climate AcHon Plan Update
Dear Members of the Planning Commission:
On behalf of the undersigned coaliHon of jobs and housing providers, we are wriHng today in support of
Items 1 and 2 on the list of staff recommendaHons and in opposiHon to Items 3, 4 and 5. Under Item 2,
we would request some minor modificaHons, to remove the requirement for electrificaHon of
construcHon equipment, as well as the expansion of the “transportaHon demand management” or TDM
requirements.
By adopHng RecommendaHons 1 and 2 with these modificaHons, you are sHll not only meeHng your
near-term goals of aZainment by 2035, you will also do so for the 2045 Hmeframe. RecommendaHons 1
and 2 allow Carlsbad to be a leader on reducing greenhouse gas emissions (GHG), while also balancing
the cost and consequences to your residents and businesses. It also helps protect against legal risk to
the City in moving forward with a de facto electrificaHon mandate through a Reach Code.
In terms of the concerns regarding the other opHons, the coaliHon is opposed to the adopHon of a
separate Reach Code. The state code, including the recently finalized triennial building code, is one of
the most stringent in the world. And the new measures under the code would conHnue to ratchet up
these GHG reducing measures in new construcHon and tenant improvements. The City’s own GHG
reducHons would significantly benefit from these changes once they go into effect. Going beyond with a
Reach Code only puts Carlsbad at a compeHHve disadvantage with your neighbors as a Reach Code
comes at a high cost, which would dramaHcally increase the cost of both residenHal housing and
commercial tenancy. It would also create legal risk, as was seen in the City of Berkeley.
The coaliHon is also opposed to the new requirements related to the electrificaHon of construcHon
equipment. In most cases, this kind of equipment is not available and, where it is, is extremely
expensive. Mass producHon at useful grade for construcHon sites is not expected for some Hme, if at all,
given the power needs for this kind of equipment. We would recommend delaying this item unHl a
subsequent update to beZ er determine the state of the market.
Regarding TDM, it is a difficult measure to implement as it’s expensive, unpopular with employees and
impossible to manage. As was noted at the previous Planning Commission hearing, Carlsbad businesses
and property owners are already avoiding triggering these requirements under the current CAP, given
their high cost. Further, depending on the TDM requirements, congesHon pricing and puniHve parking
fees would disproporHonately impact lower income workers, and for the lodging industry, dissuade
visitors from coming to Carlsbad. In short, expanding TDM would likely achieve liZ le in the way of GHG
reducHons, and create a number of other impacts, including fewer tourists, less TOT, and for those who
choose to avoid triggering the requirements, further reducing tenant improvement investments, which
would age the city’s building stock.
Lastly, we conHnue to have concerns about the lack of financial impact analysis for the proposed acHons.
While the City was willing to expend money to determine the impact to itself, it didn’t afford the same
acHon for impacts to the regulated community. We believe this kind of analysis should be done before
approval, not aGer when implementaHon is being considered.
In closing, we thank the Planning Commission and City staff for hearing the concerns of our coaliHon and
providing a reasonable, yet aggressive opHon in the OpHon 1 recommendaHon. With our addiHonal
modificaHons, we would respeceully request your support of RecommendaHon Items 1 and 2.
Sincerely,
Melanie Cohn, Biocom California
W. Erik Bruvold, San Diego North Economic Development Council
Craig BenedeZ o, NAIOP San Diego & BOMA San Diego
JusHne Murray, San Diego Regional Chamber of Commerce
Melanie Woods, California Apartment AssociaHon
Molly Kirkland, Southern California Rental Housing AssociaHon
Chris Duggan, California Restaurant AssociaHon
Lori Holt Pfeiler, Building Industry AssociaHon of San Diego
Fred Tayco, San Diego County Lodging AssociaHon
DusHn Steiner, Associated General Contractors San Diego
CC: Paz Gomez, Deputy City Manager
James Wood, Director, Environmental Sustainability
Carlsbad City Councilmembers
October 2, 2024
To: Carlsbad Planning Commission
Dear Planning Commissioners:
On behalf of the Sierra Club’s Coaster group, I’d like to share some insights with the Climate Action Plan (CAP)
update coming before you. The Coasters group includes the cities of Del Mar, Solana Beach, Encinitas, Carlsbad
and Oceanside. Our local Carlsbad Sierra Club team has had a chance to review and discuss the measures
presented within this current update.
This update is a vast improvement over the original 2015 CAP. It is much more readable and comprehensive
than the original. It will guide the city as it moves to meeting both its 2035 and 2045 greenhouse gas (GHG)
emission reduction targets.
Before addressing specific measures, we’d like to make some general comments:
• It’s unfortunate that the best GHG inventory for transportation we have is from 2016. Our city needs to
work with SANDAG to get more current data and have it done regularly on a bi-annual basis. With this
sector accounting for 50% of our emissions it’s critical that timely, reliable inventories are available to
make informed decisions.
• Factored into our targets are the contributions from state and federal actions to lower our GHG
emissions. For 2035 those combined actions account for 53% of our emissions, for 2045, 72%
(calculated from Table 2-3, page 2-8). Very few agencies are meeting their targets in a timely manner
and, therefore, the city should be aggressive in its goals to account for greater future costs and potential
shortcomings by the state and national governments.
• While outreach to specific groups, including us, has been helpful, the general public knows little about
the climate crisis and what the city is doing to mitigate it. Community workshops would be helpful to
educate the public and encourage them to take positive actions in their own lives. Make “How you can
help” a prominent link to the higher order Environmental Sustainability webpage with includes the CAP.
• Somewhere within the CAP the city should set a target date for zero carbon that is at least as aggressive
as the state of 2045.
• The city should expand its commuter mode shift goals citywide with targets to meet or exceed 50
percent walk/bike/roll/transit by 2035.
Energy measures:
E-1 – For municipal facilities consider opting up to 100% renewable energy with the Clean Energy Alliance (CEA)
sooner than later. Also, replace, at end-of-life gas appliances with electric as much as possible.
E-2 – The target date for CEA to supply all its customers with 100% renewable energy is 2035. As with the
amendment to the first CAP, clean energy through CEA is one of the best ways of meeting our emission targets so
consider a target for the city to have its default program for our residents be Green Impact (=100% clean energy)
by 2030.
Explore, Enjoy &
Protect the Planet
E-3.2 (non-residential) and E-4.2 (residential) – For new construction, now that the Berkeley case has been
finalized, proceed with reach codes that apply high-performance, electric-preferred buildings. Encinitas is
finalizing their ordinance and San Luis Obispo passed theirs last fall. Such ordinances look to optimize energy
efficiency while still allowing for gas. Because the life span for new buildings is decades Carlsbad should update
its building codes now to get the most emissions savings by encouraging electrification.
E-5 – The Building Energy Benchmarking program is being taken over from the state. We need to ensure that the
energy consumption reporting is accurate and timely and shared with building owners to help them make
decisions about becoming more energy efficient.
E-6 – Decarbonizing existing buildings will be a challenge. Therefore, aside from a target for 100% clean
electricity, steps need to be taken to reduce or eliminate gas use in our current building stock. This means
encouraging moving away from gas appliances AT LEAST at the end of their life span, if not sooner. As mentioned
earlier, most residents don’t know much about climate actions including alternatives to gas water heaters, HVAC
and cooking. Education and outreach are critical for this. The city should consider incentives to promote and
track electrification installs when pulling permits.
Transportation measures:
This sector, accounting for 50% of our GHG emissions, is the most intractable with our southern California love of
cars and independence. Bike lane and pedestrian improvements help and traffic calming measures promote
road safety and lower emissions. But getting folks out of their cars will be difficult without some incentives.
T-2 – The Transportation Demand Management (TDM) program for businesses was part of the original CAP and
didn’t have much of an impact because it only addressed new businesses. In addition, it had a somewhat high
threshold (average daily trips of >110 for employees) so only a few new businesses were mandated to have a
TDM plan. There is room to lower that threshold to include more businesses, as pointed out in the CAP update.
Also, existing businesses, particularly those large ones, should somehow be included in the program. Again, the
sooner the recruitment is increased the greater the impact on our GHG reductions. The public should get an
annual update on this program as part of the annual CAP reporting.
T-3 – While the Safe Routes to Schools doesn’t specifically cover idling, it should. Because Carlsbad Unified
School District has no school buses, the majority of our students drive themselves (high school) or have parents
drop off and pick them up. This latter group often encounters lines at the schools resulting in excess idling which
contributes to both GHG emissions and other air pollutants impacting student health. The city should be
working with our school districts to implement anti-idling at our school sites and/or promoting much higher
alternative modes of transport to and from schools.
T-7 – It’s good to see the TDM program being expanded to include city facilities/employees. The city should be a
role model for businesses in our region and this is a good way to do that.
T-8 – To increase the use of EVs the expansion of charging infrastructure is important. While the city updates its
EV Siting Plan, staff should look at the Public EV Charging Infrastructure Playbook if they haven’t already done so.
T-9 – Updating the city fleet to all electric vehicles should be the target. Last summer the majority of the council
voted to purchase 40 all gas-powered police cruisers rather than consider alternatives. Let’s hope this measure
does a better job at addressing the problem of transportation emissions even in public service vehicles than
we’ve seen recently. EVs will also have a payback in reduced maintenance costs as the fleet ages.
T-10 – Proper parking management can be a valuable tool to incentivize employees not to drive. It should be
included within the TDMs for both businesses and the city (T-2/T-7). As worded in the CAP update, this is a
rather vague measure and primarily addresses actions through existing plans like the Village and Barrio Parking
Plan rather than a city-wide business approach to reduce employee trips. Free parking is not free and the city
needs to look to the future in evaluating its parking strategies.
Off-Road Equipment Measure:
OR-1 – As written this measure only addresses gas-powered leaf blowers. As much as possible it should include
all lawn equipment. To prevent a financial hardship to landscapers, phase in this measure over 1-2 years, like
Encinitas did, to allow for end-of-life conversion to electric equipment.
Carbon Sequestration Measure:
CS-1 – Community Forest Management which includes a replacement of 2:1 for city trees should be expanded to
include HOAs which may have CC&Rs covering tree replacements. Our informal survey of some HOAs in
Oceanside found that tree replacement policies are not be followed. Hopefully, Measure CS-1.c, the 5-year
urban canopy study will include this.
In closing, we support all the measures present in the CAP update with our suggestions for improvements. The
most critical component is this: the sooner the measures are implemented the greater the GHG savings.
Global action isn’t happening fast enough. Every level of government should be doing their utmost to address
the problem. Carlsbad has the opportunity to lead by example.
Thank you for your consideration.
Paige DeCino
Paige DeCino
Sierra Club Coasters Executive Committee member
Climate Action Plan Update
Katie Hentrich (she/her)
Climate Action Plan Administrator
October 2, 2024
1
C cityof
Carlsbad
That the Planning Commission ADOPT the
following:
1.A Planning Commission Resolution
RECOMMENDING CERTIFICATION of
Addendum No. 1 to the Housing Element
Implementation and Public Safety Element
Update Supplemental Environmental Impact
Report for the Climate Action Plan Update.
CLIMATE ACTION PLAN UPDATE
RECOMMENDED ACTION:ADDENDUM
2
C cityof
Carlsbad
That the Planning Commission ADOPT one of the following:
1.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
excluding Measures E-3.2, E-3.3 and E-4.2 (Nonresidential Building Energy – Updated Reach Code, Nonresidential
Building Energy – Solar Carports, and Residential Building Energy – Updated Reach Code, respectively), to meet the
required 2045 reduction target; OR
2.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
excluding Measure E-3.2 (Nonresidential Building Energy – Updated Reach Code), which would exceed the 2045
reduction target by approximately 200 MT CO2e; OR
3.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
excluding Measure E-4.2 (Residential Building Energy – Updated Reach Code), which would exceed the 2045 reduction
target by approximately 4,000 MT CO2e; OR
4.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
which would exceed the 2045 reduction target by approximately 6,000 MT CO2e.
CLIMATE ACTION PLAN UPDATE
RECOMMENDED ACTION: CAP UPDATE
3
TODAY’S PRESENTATION
•Summary of previous PC item
•Why CAP Update is required
•Meeting vs. exceeding reduction targets
•Options
•Project analysis
•Benefit-cost analysis
•Conclusion
4
CLIMATE ACTION PLAN UPDATE
C cityof
Carlsbad
SUMMARY OF PREVIOUS PC ITEM
5
CLIMATE ACTION PLAN UPDATE
•Greenhouse gas inventory
•State targets
•Projections to determine future emissions
•Potential measures in the Draft CAP Update
•Climate equity
•Public input
C cityof
Carlsbad
6
April 6, 2021: City Council approved update to Housing Element, including land use changes to meet RHNA
April 13, 2021: staff presented CAP Annual Report 4 to City Council, discussing need to update CAP to account for land
use/growth changes included in Housing Element update and to continue to use CAP for streamlined development review
June 8, 2021: City Council approved funding for CAP Update as part of FY 2021-22 budget
Sept. 16, 2022: Assembly Bill 1279 signed into law, which requires GHG emissions be reduced by 85% compared to 1990
levels by 2045
Jan. 30, 2024: City Council certified Final SEIR for Housing Element update, including Mitigation Measure GHG-1 “Update
City of Carlsbad Climate Action Plan” within 12-18 months of adoption of the SEIR (i.e., Jan. 30, 2025 – July 30, 2025)
WHY CAP UPDATE IS REQUIRED
MEETING VS. EXCEEDING TARGETS
7
CLIMATE ACTION PLAN UPDATE
•Draft CAP Update surpasses the required 2045 reduction target by ~6,000
MT CO2e, or 0.68% of total GHG reductions
–This is combined with federal and state measures within legislatively
adjusted business-as-usual projection
•Preparing measures that surpass the 2045 target fulfills comments received from City Council Members at Nov. 7, 2023, City Council meeting
•Four options to consider
–The difference in options depends on if CAP Update meets or exceeds the 2045 reduction targets established by the state
C cityof
Carlsbad
OPTION 1
8
CLIMATE ACTION PLAN UPDATE
Description Benefits Drawbacks
•Recommend adoption of a CAP
Update that meets the 2045
reduction target
•Adopts the publicly posted Draft
CAP Update excluding the
following 3 measures:
-E-3.2, Nonresidential Building
Energy – Updated Reach Code
-E-3.3, Nonresidential Building
Energy – Solar Carports
-E-4.2, Residential Building
Energy – Updated Reach Code
•Meets the target completion date
for Mitigation Measure GHG-1 in
SEIR for the Housing Element
rezone effort
•Allows for continued streamlined
development review of projects
that show consistency with the
CAP
•Meets the minimum 2045
reduction target
•Reflects some public comment
and input provided by
stakeholders for the CAP Update
•Implements a smaller suite of
measures to meet the 2045
reduction target, which provides
less flexibility for CAP
implementation
•Delays implementation of the
CAP Update to revise the
documents (est. 1-2 mo.)
OPTION 2
9
CLIMATE ACTION PLAN UPDATE
Description Benefits Drawbacks
•Recommend adoption of the
publicly posted Draft CAP Update
that exceeds the 2045 reduction
target by appx. 200 MT CO2e, or
0.02%
•Adopts the publicly posted Draft
CAP Update excluding Measure E-
3.2 (Nonresidential Building
Energy – Updated Reach Code)
•Meets the target completion date
for Mitigation Measure GHG-1 in
SEIR for the Housing Element
rezone effort
•Allows for continued streamlined
development review of projects
that show consistency with the
CAP
•Exceeds the 2045 reduction
target by appx. 200 MT CO2e, or
0.02%
•Reflects some public comment
and input provided by
stakeholders for the CAP Update
•Implements a smaller suite of
measures to meet the 2045
reduction target, which provides
less flexibility for CAP
implementation
•Delays implementation of the
CAP Update to revise the
documents (est. 1-2 mo.)
OPTION 3
10
CLIMATE ACTION PLAN UPDATE
Description Benefits Drawbacks
•Recommend adoption of the
publicly posted Draft CAP Update
that exceeds the 2045 reduction
target by appx. 4,000 MT CO2e,
or 0.45%
•Adopts the publicly posted Draft
CAP Update excluding Measure E-
4.2 (Residential Building Energy –
Updated Reach Code)
•Meets the target completion date
for Mitigation Measure GHG-1 in
SEIR for the Housing Element
rezone effort
•Allows for continued streamlined
development review of projects
that show consistency with the
CAP
•Exceeds the 2045 reduction
target by appx. 4,000 MT CO2e, or
0.45%
•Reflects some public comment
and input provided by
stakeholders for the CAP Update
•Implements a smaller suite of
measures to meet the 2045
reduction target, which provides
less flexibility for CAP
implementation
•Delays implementation of the
CAP Update to revise the
documents (est. 1-2 mo.)
OPTION 4
11
CLIMATE ACTION PLAN UPDATE
Description Benefits Drawbacks
•Recommend adoption of the
publicly posted Draft CAP Update
that exceeds the 2045 reduction
target by appx. 6,000 MT CO2e,
or 0.68%
•Adopts the publicly posted Draft
CAP Update
•Meets the target completion date
for Mitigation Measure GHG-1 in
SEIR for the Housing Element
rezone effort
•Allows for continued streamlined
development review of projects
that show consistency with the
CAP
•Exceeds the 2045 reduction
target by appx. 6,000 MT CO2e, or
0.68%
•Includes Reach Codes that
industry stakeholders have
objected to, including on the
basis that the Reach Codes have
not been studied for cost
effectiveness*
* Prior to providing the necessary approval, the California Energy Commission requires that local
jurisdictions demonstrate that their local ordinance, or Reach Code, saves more energy than current
statewide energy standards and is cost effective.
PROJECT ANALYSIS
State regulations (CARB, targets set by CA legislature)
General Plan goals and policies
Mitigation measure in 2015 GPU EIR and 2024 SEIR
Climate Change Emergency Declaration
Five-Year Strategic Plan
12
CLIMATE ACTION PLAN UPDATE
C cityof
Carlsbad
CONCLUSION
CLIMATE ACTION PLAN UPDATE
13
•Draft CAP Update implements GP,
furthers Guiding Principles and
Community Goals, mitigates for
environmental impacts, and fulfills
regulatory requirements
•City Council will conduct public hearing
in Nov. 2024
C cityof
Carlsbad
That the Planning Commission ADOPT the
following:
1.A Planning Commission Resolution
RECOMMENDING CERTIFICATION of
Addendum No. 1 to the Housing Element
Implementation and Public Safety Element
Update Supplemental Environmental Impact
Report for the Climate Action Plan Update.
CLIMATE ACTION PLAN UPDATE
RECOMMENDED ACTION:ADDENDUM
14
C cityof
Carlsbad
That the Planning Commission ADOPT one of the following:
1.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
excluding Measures E-3.2, E-3.3 and E-4.2 (Nonresidential Building Energy – Updated Reach Code, Nonresidential
Building Energy – Solar Carports, and Residential Building Energy – Updated Reach Code, respectively), to meet the
required 2045 reduction target; OR
2.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
excluding Measure E-3.2 (Nonresidential Building Energy – Updated Reach Code), which would exceed the 2045
reduction target by approximately 200 MT CO2e; OR
3.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
excluding Measure E-4.2 (Residential Building Energy – Updated Reach Code), which would exceed the 2045 reduction
target by approximately 4,000 MT CO2e; OR
4.A Planning Commission Resolution RECOMMENDING ADOPTION of the publicly posted Draft Climate Action Plan Update,
which would exceed the 2045 reduction target by approximately 6,000 MT CO2e.
CLIMATE ACTION PLAN UPDATE
RECOMMENDED ACTION: CAP UPDATE
15